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Home My WebLink About20040801.tiff Yahoo! Mail - mol3bri@yahoosnm ry p _ \ 4 H I ' _ l-°`k c»`:-w Page 1 of 3 From: "Elmer W. Koneman" <koneman@colorado.net> To: "molly murata" <mol3bri@yahoo.com> Subject: Re: letters concerning the contamination possibilities Date: Sat, 28 Feb 2004 08:08:12 -0700 Hello Ms Murata: Thank you for sending along these letters. It appears that your situation has not been in the mainstream for most of us involved in clinical microbiology. I did receive a message from Dr. Beebe: "They should start by calling the Local health Department Environmental Health office to file a complaint." As far as the health issue is concerned, this probably is your first step. You should be able to find the number and address of your local health department office in your telephone directory. I don't know if this will be listed in the "county government"or"state government"section in the phone book. Reading between the lines, the state health department apparently does not get involved in such local affairs until after the local health department has made an initial investigation. Hope this gives you some start for a plan of action. Elmer Koneman --Original Message From: To: Sent: Friday, February 27, 2004 3:36 PM Subject: letters concerning the contamination possibilities I thought you might be interested in reading these letters I have recieved. An E-mail from John W. Foster, PhD Dear Molly, My expertise lies in understanding how food borne pathogens survive under extreme situations, such as in the low pH of the stomach. I am a molecular biologist, not a "true"food microbiologist, but based on your description of the situation, it clearly sounds like potential fecal contamination of the onions is possible if the spray reaches your facility. I am not sure what pathogens pigs can harbor, however. One of your other experts may be more knowledgeable in that area. Flies, of course, can bring fecal contamination into an area from a distance and the number of flies will surely increase once spraying starts. There should be some State regulations concerning how close fecal waste matter can be sprayed next to an agricultural storage building. Have you sought out that information? I don't know if I have been much help, but good luck. Sincerely, John W. Foster, PhD 1. EXHIBIT Professor Department of Microbiology and Immunology ,c College of Medicine 307 University Blvd .../ShowLetter?box=Inbox&MsgId=4460_1344073_34371_1665_4734_0_12780_16162_13463883/1/04 '2CY"`f-C8D/ Yahoo! Mail - mol3bri@yahoo,rnm Page 2 of 3 f? .- 1 he v e VV, yi. Mobile, AL 36688 l c' Phone: 251-460-6323 Fax: 251-460-7931 Trevor V. Suslow,Ph.D. Extension Research Specialist Postharvest Quality and Safety from Seed to Shelf c\,. P. ,�1 1. ( �Y { u : c'�t cA Trevor V. Suslow,Ph.D. Extension Research Specialist Postharvest Quality and Safety from Seed to Shelf One Shields Ave. , Uuiveisity of California Dept.of Vegetable Crops,Mann Lab Davis, CA 95616-863 tvsuslow@ucdavis.edu 530.754.8313 office 530.7524501 lab 530.752.4554 fax, http://ucgaps.ucdavis.edu .../ShowLetter?box=Inbox&MsgId=4460_1344073_34371_1665 4734_0_12780_16162_1 3 463 8 83/1/04 Yahoo! Mail - mol3bri@yahoosam Page 3 of 3 http://vric.ucdavis.edu http://postharvest.ucdavis.edu "Elmer VV. Koneman" ckoneman@colorado.net>wrote: Hello Molly: Hey--maybe I will come up to pick up a sack of onions! Hope this all turns out to your favor. Elmer Koneman I Get better spam protection with Do you Yahoo!? Get better spam protection with .../ShowLetter?box=lnbox&MsgId=4460_1344073_34371_1665_4734 0_12780_16162_13463883/1/04 c U. S. Food and Drug Administration Center for Food Safety and Applied Nutrition September 30, 2001 Analysis and Evaluation of Preventive Control Measures for the Control and Reduction/Elimination of Microbial Hazards on Fresh and Fresh-Cut Produce Table of Contents Chapter II Part 1 I Part 2 ] Part 3 j Part 4 Production Practices as Risk Factors in Microbial Food Safety of Fresh and Fresh-Cut Produce Scope The purpose of this chapter is to identify production practices that may influence thesisk of contamination and exposure tnlhe rnncnme hnnnan pathogenc Key areas of comae n are prior land use, adjacent land use, field slope and drainage, soil properties, crop inputs and soil fertility management, water quality and use practices, equipment and container sanitation, worker hygiene and sanitary facilities, harvest implement and surface sanitation, pest and vermin control, effects of.domesticated animal and wildlife on the crop itself or packing area, post-harvest water quality and use practices, post- harvest handling, transportation and distribution, and documentation and record-keeping. The role of water quality and manure management practices is particularly critical. This chapter is largely focused on practices and research originated in the United States, however the issues of concern would most likely be applicable worldwide, and therefore affecting domestic as well as imported products. Appendix A describes the results of a estate survey on local requirements regarding manure and water quality management that may influence microbial contamination of produce. This chapter is not intended to be a guide for producers of fresh-fruits and vegetables but a compilation of evidence that provides a basis for identifying sources of contamination = EXHIBIT 1 5o where they may exist. Much of this chapter is based on observation, experience, and common sense, rather than scientific research, although a review and evaluation of the literature available is included. The reader is referred to recent guides on agricultural practices for comprehensive identification of measures to minimize public health risks from consuming fresh and fresh-cut produce (Gorny and Zagory forthcoming, IFPA 1996, IFPA 1997, FDA 1998). These documents provide excellent guidance for all parties involved in the production chain, from growers to shippers, towards achieving a safe fresh produce supply. 1. Introduction The grower, packer, shipper, and handler of fresh consumed horticultural products are often faced with a labyrinth of dynamic responses to weather, pests, market value and trends, labor, and customer requests. Each decision that veers established practices may alter microbial food safety risks. The potential risk may be reduced or increased by seemingly minor deviations in timing, source of production input, degree of handling, method of cooling, or any dozens of different interacting factors. The effects are generally unrecognized, the scientific basis for the hazards is limited. The highly perishable nature of much of what is produced, the general volatility of the market, sudden swings in availability of product, and opportunities to add value by special handling or niche production create an industry that is, both conforming and highly individualized, at the same time. The diversity of cropping systems, scale of operation, use and design of equipment, regional and local practices, environmental influences, specifics of on-farm soil related factors, and many other production factors defy any attempt to develop an encompassing assignment of microbial risk to commodities or to crop management practices. This was recognized in the evolution of the Guide To Minimize Microbial Food Safety Hazards For Fresh Fruits and Vegetables(FDA 1998), which has become a template for focusing on the key areas of presumptive risk potential for fruit and vegetable production and handling. Although the available scientific literature is adequate to identify sources of contamination and estimate microbial persistence on plants, the specific influence and interactions among the production environments and crop management practices are not -sufficiently understood to provide detailed guidance to growers and shippers. Climate, weer, water quality, soil fertility, pest as well as irrigation, and other management practices are difficult to integrate towards the development and implementation of microbial risk prevention and reduction programs on the farm, Clearly, the risks associated with the purposeful introduction of pathogen-contaminated its (that is, inadequately aged manures, inadequately treated wastewater) or inajlyertent contaminatiaa(that is, irrigation water quality, wildlife activity, adiacent land use• worker hygiene and sanitation) lie been long recognized(Geldreich and Bordner 1971; Cherry and others 1972; Bryan 1977). Such risks have been thoroughly reviewed (Beuchat 1996; Tauxe and others 1997; Brackett 1999;NACMCF 1999)or summarized in the form of food safety guidelines for producers and handlers (IFPA 1997; FDA 1998; Cornell 2000). A recent overview of the anticipated persistence of pathogens on the surface of fruits and vegetables during production contrasted the characterized survival capacity of resident plant pathogens and benign microbial epiphytes (surface colonizers) with microorganisms responsible for food borne illness (Suslow 2001). Among the environmental and management factors, animal waste pollution of water and the application of managed fecal matter(that is, animal manure or human biosolids)to soil intended for edible crops are two,issues of concern during the pre-harvest and post- harvest management of fresh fruits and vegetables. A potential hazard exists for persistent pathogen populations to be transferred to harvested crops indirectly through contaminated water or by direct cross-contamination by proximity to animal production compounds or facilities, or from inadequate) coin d animal manureand biosolids (Committee on the Use of Treated unicipal Wastewater Effluents and Sludge in the Production of Crops for Human Consumption 1996; FDA 1998). These edible horticultural crops, including fruits, vegetables, edible flowers, seed sprouts, and a variety of recently domesticated wild species are typically cnnenma i u thn t a tr atment to inactivate any pathogenic.mjcroflora that may be present. The potential for contamination does not appear todepend on the size of the opera ion (small-versus large-scale operations). The extent ofpotential illness from contaminated produce is more likely to be broad in locations where large-scale animal action is immediately adjacent to edible crop production. Though not the norm, this type of situation does occur. No conclusive evidence of foodborne pathogen transfer or human illness is available that definitively links this perceptual on-farm hazard to known outbreaks. Noness_in light of current knowledge, awareness, and consumer perceptions and concerns regarding fresh produce, research directed towards characterizing and quantifying.he risk seems prudent(Rose and Gerba 1991; Atwi11 and others forthcoming). Successful programs, such as training on pathogen prevention and control methods for all parties involved in the fresh produce production chain are already being offered by experts in Universities and Trade Associations. 2. Pre-harvest Operations A schematic for pre-harvest operations is given in Figure II-1. Although each crop experiences particular conditions at each step of the process, some potential points need to be given careful consideration. These points are key elements to ensure the safety of the final product because they can introduce pathogens that may persist and reach the consumer. It is important to recognize these points, get the appropriate information, and develop strategies to reduce the risks. The most important considerations are the quality of the water used during irrigation or various foliar applications and the application of manure, biosolids or compost as fertilizers. They will be the focus of this chapter because of their most direct potential implication in contamination (sections 2.1. and 2.2.). While other pre-harvest circumstances may be equally significant, research to assess their impact in food safety is lacking. For instance, the selection of land that has no recent history of manure use or animal grazing or farming activities would be a preferred location. Distance limits to adjacent animal farm activities should be considered, and the possibility of contaminated run-off should not be overlooked. These factors will be discussed in the context of water quality (section 2.2). Finally, there are additional factors whose contribution to increasing food safety risks may be of a more indirect source. These include transfer of pathogens through wild and domesti orals, vermin, and aerosols. Section 2.3. describes some of the research that has been published in an effort to evaluate the risks from these sources. Figure II-1. Potential control points to reduce microbial hazards in fresh produce during pre-harvest field operations Field Operation Potential Risk-Reducing Control Point Crop site Soil, water, wild and domestic animals, drift and run-off from adjacent selection farms, prior land-use history Land preparation Pre-plant fertilization Biosolids/manure Planting Irrigation Irrigation water, irrigation method In-season fertilization Foliar applications: water quality Irrigation Irrigation water, irrigation method Pest Control Wild and domestic animals, vermin Dust control: spraying roads Water quality and paths with water 3.1. Manure and biosolids 2.1.1. Description of the situation Animal manure is commonly used as a crop fertilizer worldwide. In the United States r excess animal manure may be spread on land in the vicinity of animal or produce farms due to high transportation costs. Although, according to an USDA survey (USDA 2001), organic sources of fertilizers are not commonly used by conventional fruit and vegetable growers, they are readily used by organic producers. `A A large number of factors influence the probability of human pathogens being established on produce(for example, loca_n, soil microflora, rain, and irrigation). Enough; scientific evidence suggests that humanpathogens may be transferred to existing adjacent crops by a variety of physical r prior to (for example, w.) or during soil incorporation of organic soilamendments (Ahmed and Muller 1984; Jones 1999; Gagliardi and Karns 2000; Hossain and others 2000; Abu-Ashour and Lee 2000; FengYu and others 2000; Wamemuende and Kanwar 2000). There are multiple potential sources of contamination (Beuchat and Ryu 1997): animal and human feces conjaminated raw manure, irrigation water, water used for pesticide application or other agricultural purposes, contaminated dug, vermin and insects as vectors in fecal matter, and transfer by or on fa„r, equipme t. Significant populations of Escherichia coli and related pathogens of fecal origin are probably limited to soil contaminated with fecal material and are widely held to be transitory. Soil per se is not an important source of enteric pathogens on plants (NACMCF 1999). Fecal contamination of irrigation water, however, may be an important source, and other pathogens may be present in feces and have a recognized soil residency. Also, it is known that Listeria monocytogenes exists as a soil resident associated with decomposed organic mater(Dowe and others 1997; Porto and Eiroa 2001). Animal manure has been used for thousands of years as a soil amendment to increase or maintain the organic matter content, biological diversity and activity, and soil aggregate stability of agricultural soils (Brady 1990). Animal manure contributes to the fertility management of soils, particularly nitrogen, and may be the primary source of plant nitrogen in organic farming systems. However, outlets to agricultural land are not always an option and in many regionally concentrated animal production Systems (including pi_ ati,ry and poultry) the disposal of manure has become a significant issue and waste management problem (EPA 2000). In many areas of the United States, manure is accumulating in excess of that needed for application to on-farm or local forage production areas. Animal manure is often contaminated with human pathogens This waste management issue is believed to be a key contributor to an intimately related potential source ofproduce contamination, water. For example, the annual animal waste production in the United States is estimated to be 1.36 billion tons, compared to a volume of human waste of over 64 million tons (EPA 2000). Animal production operations are increasingly concentrated, and large dairy operations are characteristic in states such as California, a major producer of fruits and vegetables for domestic and export markets. This large volume of waste must find an outlet as material for on-site bedding, on-site land application, and off-site land or farm distribution. Dairy and feedlot production facilities are the largest producers of waste volume and may be sources of Salmonella spp.,E. coil O157:H7, Cryptosporidium parvum, and other potential human pathogens, although other farm animals may also be pathogen sources. The risk waterpallution and contamination front waste spills, run-off, seasonal flooding, and lagoon leakage is increased. Although a significant number of outbreaks of human foodborne infections have been linked to consumption of raw fruit and vegetable products such as unpasteurized apple juice, pre-sliced melon, lettuce, and sprouts,the epidemiological association of outbreaks to the use of aged manure or compost in the United States is still speculative. Acquisition of pathogens from pathogen-containing soil amendments has been demonstrated (Bryan 1977 and references therein), but, although possible, there is no demonstrated evidence that pathogens incorporated as soil amendments prior to planting can persist until harvest and be transferred to the edible portion of the crop. Although direct evidence of food- , associated illness due to contamination of prodhc@,_}`turn any source during commercial production is sc apidemidogical evidence, primarily related to fresh leafy greens fruit-ve has imnliccgted poor production practices and poor animal waste and mange nrncess control practices. It is reasonable to believe that as a result of sub-standard or even illegal aQncultural practices, produce may hacontaminated with human pathogens. The National Advisory Committee on Microbiological Criteria for Foods (NACMCF)lists 11 agents associated with produce-borne outbreaks. Foremost among them are E. con O157:H7 and various Salmonella serotypes (see Chapter IV and Tauxe 1997). Health officials at a recent national food safety meeting disclosed preliminary data, which demonstrate that foodborne illness associated with fresh produce in the United States is related predominantly to pathogens of animal origin. Illness attributed to imported produce predominantly aligns with human sources of contamination. Comparable findings have been reported from earlier studies with environmental sources of Salmonella spp. and clinical salmonellosis (Dondero and others 1977; Jones and others 1980; Garcia-Villanova Ruiz, Cueto Espinar and others 1987). This is an interesting and important area of future research that is critical to better identify the environmental sources of contamination. In addition to information on pathogen origin, there is an ongoing need for multidisciplinary research on industry practices patho istence and pathogen reduction practices for manure intended for soil incorporation on fruit and vegetable farms or direct crop applicati ns as foliar sprays. 2.1.2. Factors affecting contamination of fruits and vegetables It has long been known that the improper use of manure can transfer pathogens onto crops, resulting in human disease. Raw manure should not be applied to crops. In 3drtion to the hazard of pathogen transmission, it is well recognized that salt injury to sensitive vegetable crops and transfer of viable weed seed may result unless the manure is subjected, at least, to a period of unmanaged (no thorough mixing or pile inversion) composting. This "stacked" or "aged" manure is applied at various limes and amounts to a variety of production soils. According to a USDA survey, among conventional growers, only 6% of fruit acres and 3% of vegetable acres were reported having manure applied in 1999. Only 2% of all fruit acres and 1% of all vegetable acres received sludge applications in 1999 (USDA 2001). The survey also reported that of the manure users, 22% and 15% of fruit and vegetable farms, respectively use untreated manure. However, among the growing sector of organic producers that cannot use synthetic fertilizers according to the USDA standards, the practice of using manure as a fertilizer is more spread. Very few studies have been performed to address the microbiological safety of broadcast spreading, feeding of whole cottonseed or hulls or alfalfa, and accessibility of seed to birds.Arcobacter sp., possibly an emergent pathogen, was also present in 14.3% of individual fecal samples of healthy cattle (Wesley and others 2000). Regardless of the high variation in shedding contamination from farm surveys, there is no doubt that on- farm food safety would still benefit from programs that identify animal production practices that minimize pathogens in the manure management system (EPA 2000). Escherichia coli prevalence More current data on shedding of shiga toxin-producing E. colt O157 by cattle indicates that the prevalence may be higher than suspected, partly due to improved methods of detection (Gansheroff and O'Brien 2000). For example, from a total of 365 fecal samples of cattle,E. colt O157 was found in 20%of samples in an intensive management beef cattle farm in the Csech Republic using selective enrichment followed by immunomagnetic separation(Cizek and others 1999). A Dutch study reported that 7 out of 10 cattle farms tested positive for verocytotoxin producing E. colt O157 with the prevalence ranging from 0.8-22.4% (Heuvelink and others 1998). A 15 mo follow-up study showed that farms that were negative in the first visit would later become contaminated with the pathogen. Characterization methods implied that there was more than one source of verocytotoxin producing E. colt O 157 on the farms. The study also demonstrates that testing for the pathogen during a single visit to a farm does not demonstrate verocytotoxin producing E. colt O157. Age of cattle seem to be a factor in pathogenic E.colt shedding in that younger cattle and calves at weaning seems to have higher feces prevalence than older cattle(Laegrid and others 1999; Heuvelink and others 1998). A recent USDA survey to estimate the frequency of enterohemorrhagic E. colt O157:H7 in feces at slaughter houses showed 72% of 29 lots had at least one positive fecal sample(Elder and others 2000). Among individual cattle the prevalence was 28% overall. High prevalence was also reported by a Canadian study performed in cattle fecal samples at the point of processing(van Donkersgoed and others 1999). Salmonella spp.prevalence Salmanella spp. may be detected in both cattle and poultry manure. The prevalence among dairy herds may range from 57 to 84% (Smith and others 1993; Atwill and others forthcoming and references therein). Shedding is predominantly discontinuous, even in herds with a high positive recovery frequency. Less then 4%of healthy cows that were determined to be asymptomatic carriers of Salmonella Dublin were found to be shedding at any sampling date(Smith and others 1993). A singular assessment of feedlot cattle (Committee on Salmonella 1995)indicated that Salmonella could be recovered from 38% of a composite profile of feedlots but the percentage of individual positive samples would be 5%or less, depending on the length of time on supplemental feed. Despite the high prevalence, there is insufficient information to predict the residual viable populations of Salmonella spp. shed (CFU/g) in manure. Estimated numbers in manure slurry from colonized livestock herds are reported to be from less than 2 to 5,000 CFU/g-wet weight (Atwill and others forthcoming). By extension, a crude estimate of 20 to 50,000 CFU of Salmonella/g of manure may represent a typical initial load before aging or composting. The frequency of shedding and numbers of Salmonella per gram of chicken manure are not readily available. In a California survey, Riemann and others(1998)found that chicken manure piles in 68% of layer houses were positive for Salmonella with a broad range of detection(25 to 100% of replicate samples). The estimated numbers of Salmonella per gram feces from layers, reported in this study, range from 0.68 to more than 340. Another survey in the Netherlands and Belgium to investigate the microbiological contamination level of raw sludge at pig and chicken slaughter houses revealed that Salmonella spp. were present in all samples. Prevalence of other human pathogens Other n were also detected in high numbers such as ho enic Yersinia nterocnlitica(detected in 7 out of 13 slaughter houses) and Campylobacterjejuni/coli (2.8-7.3 log/g in 10 out of 14 slaughter houses) (Fransen and others 1996). Gregory and others(1997) also reported a high prevalence of Campylobacter spp. in broilers cecal droppings (100% of 20 samples were positive), even for newly constructed houses. Similar data was presented by Stem and others(1995) where average levels of Campylobacter spp were 5.44 log/g cecal material in 9 out of 10 broiler farms and increased significantly after transportation. Farm practices and Escherichia colt In an effort to minimize the level of pathogenic organisms at the source, research is being increasingly directed to the identification of specific farm management practices that may be linked to the incidence of pathogens in animal manure or in the farm environment. For example, the prevalence of E. colt O157:H7 was investigated on 91 dairy operations in another USDA attempt to identify management practices associated with pathogen prevalence on farms. In 24.2% of the operations, 1.2% of samples were positive for verotoxin-producing E. colt O157:H7. Herds on farms that did not flush manure with water had significantly fewer positive samples for verotoxin producing E. colt O157:H7 (Garber and others 1999). Other factors, such as chlorination of cow's drinking water and feeding practices, seemed to have an effect but were statistically insignificant. A higher number of positive samples for the pathogen in the feces were also associated with the summer months. Several recent studies point out that among farm practices, animal diet may influence pathogen shedding (Diez-Gonzalez and others 1998; Hovde and others 1999; Herriot 1998; Dargatz and others 1997; Buchko and others 2000). A grain diet may induce changes in the cow's digestive system that promotes the survival of acid-resistant E. colt (Diez-Gonzalez and others 1998; Hovde and others 1999). Grain-fed cattle shed 1000- fold more acid-tolerant E. colt than hay-fed cattle, and had lower colonic pH. Similarly, from a total of 36 samples, herds fed corn silage had higher numbers of E. colt O157:H7 than those that were not. Other associated factors included the weaning method,protein level of calf starter, and feeding of ionophores (that is, lasalocid and monesin, feed supplements introduced in the 1970's),grain screens, or animal by-products (Herriot 1998). Other studies also suggest the influence of animal diet on pathogen incidence (Dargatz and others 1997). Minimizing environmental dissemination of E. coil O157:117 in conjunction with diet modification may reduce numbers of E. coil O157:H7-positive cattle, according to an inoculation study (feed was inoculated with 101°CFU of E. coil O157:H7) that found that corn-fed or cottonseed/barley-fed steers were less likely to be positive for E. coli O157:H7 than steers fed only barley. As in the study by Diez- Gonzalez and others (1998), a lower pH of the feces in the corn-fed animals was suggested to contribute to this difference (Buchko and others 2000). Other studies suggested an association between verotoxin producing E. coli strains management practices other than feed (that is, a larger herd size, open pile manure storage, and occasional use of equipment to handle both manure and feed) (Bormaneby and others 1993). In a Washington state study of 60 dairy cattle and 25 beef cattle , E. coli O157:17 was found in 0.28, 0.71, and 0.33% of the fecal samples from dairy, pasture beef, and feedlot beef cattle, respectively. As many as 16% of the beef cattle and 8.3%of the dairy cattle herds were infected. In this case, management practices also seem to be able to reduce human exposure to E. coli O157:17 (Hancock and others 1994). However, when a larger study was designed and herds selected to prove this hypothesis, the prevalence of E. coli O157:H7 (1.41% of positive individual fecal samples out of 12,664 samples over 6 mo and 75% positive herds out of of 36 ), neither the application of manure to forage crops nor the housing in dry lots (as opposed to grazing in pasture) nor the grazing in pasture were associated with the prevalence of the pathogen (Hancock and others 1997). Fann practices and other human pathogens The influence of management practices in the prevalence of other pathogens in feces has also been investigated. For instance, in one study the probability of having a positive pigeon fecal sample for C.jejuni was decreased by using dry manure in nesting, cleaning shipping crates, and by decrease frequency of chemical disinfection of water(Jeffrey and others 2001). Presumably, the use of manure as part of the nesting material protects the pigeons against C.jejuni infection. This would agree with the competitive exclusion principle, demonstrated in poultry. The authors recognized that critical control points for food safety pathogens may vary widely, and the formulation of effective programs depend on science-based knowledge of diverse animal production systems. Likewise, as part of a large United Kingdom project, another survey indicated the excretion of L. monocytogenes(including virulent strains)by farm animals (pig, poultry, sheep, and cattle)was associated with long distance transportation of animals and their diet(Fenlon and others 1996). The studied showed that animals fed on silage, commonly contaminated with the pathogen, shed L. monocytogenes, whereas in animals fed on hay or manufactured diets L. monocytogenes was not detected. Eleven dairy farms from the northeastern region of the United States were sampled for Cryptosporidium in farm and stream water and feces over a 6-month period (Sischo and others 2000). Ninety one percent of the farms had Cryptosporidium on their premises. The single risk factor for detecting Ctyptosporidium in surface water was the increasing frequency of spreading manure in fields. Shedding cryyptosporidia was associated with young calves (15% of calves 0-3 wk of age) and frequent contact and change of bedding. Based on these studies on farm management practices, current knowledge does not allow for a clear association between certain farm practices and pathogen shedding. The results are difficult to interpret mainly due to the variability in practices and interaction with other factors that might have been overlooked. Despite the variability certain practices need to b rther. These include theinfluence of diet and the management an use of manure. With the current trends to minimize the incidence of pathogens at the point of origin, future research should focus on farm practices. 2.1.2.2. Manure storage and processing methods Proper storage and management of manure includes anaerobic digestion, aeration of sludge, and composting. These practices greatly reduce residual pathogen populations in contaminated manure. Proper manure management, often called aging, is essentially a heat-pasteurization process, generally targeted to maintain between 60 and 65 °C ( 140- 149 °F) (Kudva and others 1998; Berg and Berman 1980; Burton 1996). There are however insufficient data from controlled studies in which the fate of foodborne pathogens has been determined. Although many years ago, it was thought that pathogen persistence did not usually become an issue of risk if animal bedding is ultimately mixed with or used for soil amendments (Strauch 1977), the current situation may require different manure management methods. The increase in biosolids production and waste disposal issues, as well as the emergence of new pathogens of concern call for more dated scientific validation procedures. With minimal supporting data, EPA stated that this pathogen reduction step is best accomplished by composting, but aging(stacking) for at least 3 d at 131 - 149° F (55 - 65° C)is effective, if done thoroughly (EPA 1993). Composting, as compared to aging, is a more directed aerobic fermentation which involves the same target degree of temperature increase, but includes the provision that all material must be turned to maintain aeration, that moisture be added, and that the process be allowed to reach a peak microbial composition over a period of at least 3 mo. The need for scientific validation studies of pathogen reduction in manure is an eminent ned and consequently this is an active area of research. Previous scientific studies that assess population fates and kinetics in pathogen-bearing manure are sparse. Porter and others (1997)only detected E. coli O157:H7 in manure with a high moisture content. Salmonella cultures dried on polyester sheets and buried in cattle manure survived at 5 - 300C (41-86 °F)for up to 105 d (Plymm-Forshell and Ekesbo 1993); at 1 - 15°C (36.5-59°F)detection was positive for up to 210 d. Simulating the temperature increase during aging, Salmonella survival on the inoculated sheets was detectable for at least 8 d at 50 - 62°C (122-143.6°F). The potential for reduced recovery of stressed cells within the recovery protocols was not specifically addressed. Plymm- Forshell and Ekesbo (1996) determined that Salmonella Dublin inoculated into dried fecal material on a stall surface survived for 68 mo at ambient temperatures. When applied as slurry, populations were reduced by 3.0 log, but not eliminated, following approximately 4 d of rapid drying conditions. In contrast E. coil O157:H7 could not be obtained from the dry outer surface layer of pathogen-containing ovine and cattle manure piles(Kudva and others 1998). This study was done to determine the persistence of E. coil O157:137 in manure under various experimental and environmental conditions. When ovine and bovine manure were inoculated and periodically aerated, E. coil O157:H7 remained positive for 4 mo and 47 d, respectively. The pathogen survived best without aeration at 23 °C (73.4 °F). In frozen bovine manure or at 4 or 10°C (39.2 or 50 °F) in ovine manure, the microorganism survived for 100 d. Under other conditions (23, 37, 70 °C) (73.4, 98.6, 158 °F)the microorganism survived between 1 and 47 d (Kuvda and others 1998). Another study reported that over a 12 wk period at 10 °C (50 °F) a 3.5- and 5.5-log reduction was observed in the E. coil O157:H7 population that was inoculated in slurry from cattle fed different diets. This persistence of E. coil O157:117 indicates that the pathogen has the potential to be transmitted to the environment (McGee and others 2001). Such long-term survival ability emphasizes the need for including treatment of manure as a management practice to eliminate this pathogen as a primary source of food and water contamination and to minimize human health related risks. The efficacy of the process, though, can be improved with different experimental protocols. For instance, composting under intermittent aeration with a blower control system and at least 60°C (140 °F) killed E. coil in 24 h and was not detected after the fermentation period (30 d) (Mori and Sakimoto 1999). The survival of other human pathogens such as Salmonella Enteritidis under different conditions and experimental protocols has also been investigated. Salmonella Typhimurium was not recoverable at 44 d at 10°C (50 °F) and by 3 d at 35 °C (95 °F) in dairy lagoon water(McCaskey and Jaleel 1975). Slurry materials commonly remain in lagoons for storage periods that exceed 5 mo. Lagoon capacity and prevention of leakage or storm-related spills and run-off may become a significant concern if the production location will induce downstream crop or groundwater contamination. Compared to dairy manure, a higher ammonia content(0.2-0.4%) and alkaline pH(8.6)found in chicken litter would be predicted to accelerate Salmonella inactivation of 7.0 log within 11 d (Turnbull and Snoyenboss 1973). Recent studies (Himathongkham, Bahari and others 1999; Himathongkham, Nuanualsuwan and others 1999; Himathongkham and Riemann 1999; Himathongkham 2000; Himathongkham, Riemann and others 2000) confirm that after a short term of multiplication in fresh moist manure, there is an approximately logarithmic decline for both E. cols O157:H7 and Salmonella Typhimurium. The rate of inactivation and the decimal reduction time (D-value)varied with temperature and origin of manure and was different for manure and manure slurries. At 37°C (98.6 °F), the fastest reduction of inoculated E. toll and Salmonella Typhimurium in cow manure and manure slurry occurred. The decimal reduction time ranged from 6 d to 3 wk in manure and from 2 d to 5 wk in manure slurry (Himathongkham, Bahari and others 1999). According to the authors, the D-value could be used to predict the time and temperature needed to achieve a desired reduction of pathogen level. An additional issue that may become a concern ist.he existence ortleyelhp1_nent of microorganisms tot Bran+rn ligh+emperatwes: The high temperatures that evolve during aging and composting may induce resistance within the microbial population or survival of resistant microorganisms through selection processes. Thermotolerant(also thermophilic mutants)E. colt and Salmonella Typhimurium have been reported from composting material. Brinton and Droffner(1994)reported a maximum growth temperature for an enriched variant of E. coil and Salmonella Typhimurium of 48 and 54 °C (118.4 and 129.2 °F), respectively. Survival of both inoculated strains was at least 56 d in compost maintaining 60 °C (140 °F). Thermotolerance was inducible and reversible when the strains were grown at lower temperatures. This phenomenon, however, has not been reported during the commercial production of manure. Although phenotypic thermotolerance constitutes a potential concern during manure management, it is not a required phenomenon for the presence of persistent pathogens in manure piles. The outer layer of a manure pile may be as much as 35 °C (63 °F) lower than the interior, and never exposed to temperatures sufficient to kill pathogens if not specifically turned(Suslow and Meyer; unpublished data; unreferenced). Unless specifically prevented by a company operational policy, manure handlers may add new manure to an existing manure pile; any mixing or inversion may be limited to pile movement with a front-loading scraper. Desiccation at the outer layer will result in inactivation. Death of E. colt O157:H7 and Salmonella Typhimurium was limited to 1 to 2 logs in slow drying manure over 24 h (Himathongkham and Riemann 1999),whereas fast drying resulted in up to a 3-log decline in just 6 hat approximately 22 °C(71.6 °F) (Himathongkham, Bahari and others 1999). However, residual populations remain viable for a long time despite low water activities(a.). A 6-log reduction was estimated to take 3 mo at very low aw and 20 °C (68 °F). When manure piles are turned, the previous surface layer will be exposed to different conditions (for example higher moisture content)in the deeper part of the stack. Remaining viable pathogens presumably die as temperature elevation occurs. In piled poultry manure, ammonia generation causes as rapid a reduction and elimination of pathogens in the top layer as in the deeper layers (Himathongkham and others 2000). Certain protozoa are alto important disease-ca„si a ^Ants in Europe and Norrh_America, although the vast majority of them are not lethal. Potential sources of contamination are water and biosolids for land application. Conventional aerobic and anaerobic wastewater treatment in Ottawa consists of screening, primary clarification, aeration, secondary clarification, and anaerobic digestion. One study compared the extent of Cryptosporidium and Giardia reduction to that of other pathogenic and indicator microorganisms during conventional treatment. During aerobic treatment, Cryptosporidium and Giardia cysts were reduced by 2.96 and 1.40 log(from an initial population of 3.68 log and 3.92 log), respectively. After further anaerobic treatment,there was no significant reduction for any protozoan organisms tested while a 1-2 log reduction of fecal coliforms was observed (Chauret and others 1999). Another study showed that no Cryptosporidium muris oocysts were detectable after 44 d of fermentation of bovine feces and rice hull at 73 °C (163.4 °F)from an initial load of 2.26 x 105 oocysts/g of compost(Furuya and others 1999). Recently, the new experimental data(Table II-1; Cliver and others 2001)were combined with previously published information to assess the risk to consumers of growing lettuce with manure as a soil amendment. Application of raw bovine or poultry manure to a lettuce field shortly before harvest presents a considerable risk to the consumer. Poultry manure stored for 2 mo at 20 °C (68 °F) and applied to the field 2 mo before harvest represents negligible risk with respect to Salmonella or E. coli O157:117. In contrast, cattle manure used the same way seems to represent an unacceptable risk. Table II-1. Estimated times for 100,000-fold reduction of Escherichia coli O157:117 and Salmonella in different manure preparations. Material Temp., °C Days Reference Cattle manure 5 70 Wang and others 1996 4 100 Himathongkham,Nuanualsuwan and others 1999 4 20 Kudva and others 1998 20 57 Himathongkham, Nuanualsuwan and others 1999 22 56 Wang and others 1996 23 40 Kudva and others 1998 37 49 Wang and others 1996 37 8 Kudva and others 1998 37 36 Himathongkham,Nuanualsuwan and others 1999 Poultry manure 4 70 Himathongkham and others 2000 20 8 37 3 37 8 Williams and Benson, 1978 Cattle manure slurry 4 25 Kudva and others 1998 20 20 Porter and others 1997 20 5 Plymm-Forshell and Ekesbo, 1996 23 5 Kudva and others1998 37 8 Slurry,fresh manure 4 92 Himathongkham,Nuanualsuwan and others 1999 20 69 37 14 Slurry, old manure 4 261 20 26 37 12 Slurry, poultry 4 223 Himathongkham and others 2000 manure 20 34 �^ 37 9 Other materials Soil 20 36 Rickle and others 1995 20 28 Zhai and others 1995 20 94 Himathongkham and others 2000 Soil + manure 20 66 Soil + straw 4 69 20 71 37 13 Reproduced from Cliver and others(2001)by permission of Dean 0. Cliver. The difference between poultry and cattle manure is mainly due to a more rapid die-off in poultry manure because it accumulates ammonia. Manure mixed with bedding, resulting in self-generated heat of 60 - 70 °C (140-158 °F), is assumed to present little risk. To estimate overall risk to consumers of raw produce,the data and models must be carefully scrutinized; data describing present manure handling practices are also needed. This se^cti leariv demnnstratetthe importance of developing manure treatment protocols that efficiently reduce the nathogepir n�nulation to a level that minimizes the risk of fresh produce-derived illness. A number of technical difficulties still need to be resolved before a manure treatment protocol can be suggested. Those include sampling protocols, aeration and turnover methods, and addition of fresh manure. Furthermore, because several other factors contribute to the further reduction or growth of the pathogens,the desired level of reduction is still a matter of discussion. When assessing the risk of contamination from pathogenic organisms in manure, one needs to consider a number of additional environmental parameters. A recently published book chapter (Suslow 2001) discusses the further reduction of residual pathogen populations following soil incorporation by desiccation on the plant surfaces, by ultraviolet (UV) exposure, or other environmental stresses. The reader is also referred to Chapter IV on pathogen growth and survival on produce. 2.1.2.2.1. Regulations The current regulations found in EPA 40 CFR Part 503 for use or disposal of domestic sewage sludge are derived from regression analysis studies of compost research and thermal inactivation analysis in model matrices (Farrell and others 1990, 1996). Beyond limitations in the ability to predict the environmental fate of key pathogens in the diverse physical and chemical environments of soil, varied climates, specific seasonal weather events, and soil management practices, pathogen elimination is predominantly an issue of uniformity and consistency of process controls(CCREF 2001). EPA 40 CFR Part 503 estates Class A sewage sludge can be used without restrictions and must contain <1,000 Most Probable Number(MPN)/g total solids or< 3 Salmonella sp. MPN/4 g total solids. In addition the temperature of the sewage sludge must be maintain at a specific value for a minimum period of time, depending on the percent of solids and the treatment method (usually 50-55 °C [122-131 °F] or greater for 4 h-15 d). Different methods of pathogen reduction are described such as aerobic and anaerobic digestion, air drying, or composting. If sewage sludge does not meet the standards above, it may be classified as Class B. Class ft-sewage sludge must contain <2, 000,000 MPN fecal coliforms/g total solids (Class B pathogen limit, Part 503 rule). It should be noted that in this regulation, the fecal coliforms and Salmonella standards are used as indicators of the process, not the presence of pathogens. Strong statistical evidence, however, suggests that pathogens may be present when indicator microbes are present at this level (Farrell and others 1990). Therefore,this material could not be used or sold for use on vegetable crops or distributed to the general public without management requirements and site restrictions. Class B product can be used on crops that will be_consumedby humans or animals; however, there are requirements for waiting periods between the lime of ap li a ion and crowharvest and for restricting public access. The amount of waiting time required depends on various factors (for example proximity of edible part of the plant to the soil), details of which are readily available in the Part 503 rule. States may have more restrictive and independent rules for biosolids use and reporting(see Appendix A). As a precaution, produce buyers are using market pressure to preclude growers from producing fruits and vegetables on ground with a prior history of biosolid application. Manure, however, is exempt from these regulations. There are no federal or state rules regarding pathogen levels in aged manure used for land application. Although no such specific rules (federal or state) currently apply to aged or stacked manure use and distribution, the time-temperature criteria for pathogen reduction and elimination by composting are being broadly used. Also, certified organic growers must follow certain standards to satisfy the criteria for certification. For example under the new USDA organic certification program the raw animal manure must either be composted applied to land used for a crop not intended for human consumption, or incorporated into the soil at least 90 d before harvesting an edible product that does not come into contact with the soil and at least 120 d before harvesting an edible product that does come into contact with the soil. Composted plant or animal materials must be produced through a process that achieves a temperature between 131 °F (55 °C)and 170 °F (76 °C)from 3-15 d depending on the composting system. As previously mentioned, sublethal exposure due to inadequate time-temperature management in aged manure composting may yield soil amendments,which have pathogen numbers similar to Class B biosolids compost. A high degree of uncertainty remains about the efficacy of the treatment and usefulness of indicators as presumptive evidence of the absence of pathogens. Besides the uncertainty regarding the efficacy of the treatment, additional research on persistence in soil and on plant surfaces is needed to support science-based policy decisions on restrictive limits. 2.1.2.2.2. Current situation In practice, detectable populations of nonpathogenic E. coil,which serve as indicators of survival potential, are commonly found in stored stacked manure piles and field-side piles prior to spreading. Populations of E. coil in aged piles or field-side windrows of dairy manure are reported to range from undetectable (less than 100 CFU/g by most enrichment-based methods)to greater than 1,000,000 viable bacteria per gram_ Viable E. coil and Salmonella have been detected in manure piles over a broad range of collection- point temperatures, including sub-surface samples measured at 52 °C (125.6 °F) (Suslow, Meyer, and Cliver; unpublished data; unreferenced). Temperatures below the surface of manure piles, routinely taken at 1 m depending on the size of the pile, exceeded 65 °C (149 °F), while a layer just under the surface may be below 35 °C (95 °F). In addition to temperature fluctuations, other factors such as water activity, pH, ammonia concentrations, and microbial activity affect the rate of loss of pathogen viability in stacked piles. Over wintering, manure piles on the side of the fields may harbor high populations of E. coil, although surveys for the presence of key pathogens have not been publicly reported. Studies with E. coil O157:H7 and Salmonella Typhimurium predict a survival period exceeding 100 d from a starting population of one million cells in both chicken and dairy manure (Himathongkham, Bahari and others 1999; Himathongkham, Nuanualsuwan and others 1999). Aerobic composting is preferred for manure intended for fruit and vegetable production because it results in a stabilization of nutrients. It is important for the added manure to have nutrient release characteristics that meet the fertility management plan and projected sufficiency demand of crops throughout the season (Smith and others 1998; Lubke 1995; Nelson and Uhland 1955). For this reason,manure may be applied after short-term storage,just enough to be manageable with a conventional spreading system, but without a more intensively managed compost processing. In some regions of the United States, manure may be applied to land as slurry, often untreated or minimally treated to avoid the cost of construction and nuisance reduction and environmental protection management requirements of large storage facilities and pits. Typically this slurry would not be applied to fruit and vegetable production ground (certainly no major production area), but may be a source of contamination by run-off(see section 2.2.). 2.1.2.3. Biological and physical buffers The survival of residual pathogenic bacteria from manure in the farm soil environment is thought to be largely an outcome of competition from the existing soil microflora(Lynch and Poole 1979; Killham 1995; Tate 1987). It is well established that populations of introduced bacterial inoculum to soil are rapidly reduced due to competition from the endemic microflora. Recent research, with better methods of recovery, however, suggests that pathogens adapted to the gastrointestinal environment have an uncertain period of persistence in soils, depending on several factors. This is a primary area of focus in current food safety research, and related findings are just starting to become available (Atwill and others forthcoming). Soils with relatively low microbial activity are believed to allow the extended persistence of pathogens. Therefore,the application of large quantities of manure to soils with low existing microbial activity is thought to increase the ability of pathogens to persist in the soil environment. The soil type and matric potential (soil moisture levels) also influence the survival of introduced microorganisms (Henschke and others 1991; Drahos and others 1992; Meikle and others 1995). It has been shown that well-aggregated soils that have a high organic content result in high soil microbial activity and generally poor persistence of introduced microorganisms (Killham 1995). Few direct quantitative data are available, but risk assessment studies and persistence data generated during the early years of concern regarding the release of recombinant soil bacteria and recombinant microbial pesticides for agriculture strongly support a low probability of persistence of enteric pathogens in soil. Salmonella In a study of potential indicator microbes, fecal coliforms, as a group, showed a biphasic logarithmic death curve in soil amended with poultry manure and a moisture content of 15% (Zhao and others 1995). The initial decimal reduction time (D-value) was approximately 4 - 5 d, followed by approximately a D-value of 15 - 20 d for the residual population. Rickle and others(1995)found that zeolite and similar materials that absorb water, ammonia, and other compounds had little impact on survival of Salmonella Typhimurium in soil. Survivor curves over 29 d were approximately exponential with a D-value of 2.3 - 3.6 d at 35% moisture. With increasing moisture, the D-value increased to 12 d. In a study by Zibilske and Weaver(1978), Salmonella Typhimurium was not recoverable in one week in dry soil at 39 °C (102.2 °F). At the time of manure incorporation, however, such high soil surface temperatures are limited to certain regions of the United States. Thus, the model data are not generally instructive in crop management decisions relative to food safety. Moreover, manure incorporation into the pre-irrigated soil would be unlikely at these temperatures except under atypical conditions or practices. In model studies at more common soil temperatures of 5-22 °C (41-71.6 °F), soil survival for more than 50 d is widely reported. Himathongkham (2000) observed a D-value value for E. colt O157:H7 and Salmonella Typhimurium of 14 d in clay soil (pH 8.9, moisture 22%) at 20 °C (68 °F). Mixing manure into the soil (1:5) did not change the D-value. Controlled studies that address the impact of soil matric potential cycling (wet-dry cycles) and subsequent field preparation activities (that is, discing, bed- shaping, pre-plant irrigation) on survival are not available. Escherichia colt When the persistence of E. colt O157:H7 in river water, cattle feces, and soil cores were investigated with model systems, survival was greatest in soil cores with rooted grass, decreasing only from 108 to 107-106/g soil after 130 d at 18 °C (64.4 °F). The organism also survived in feces for more than 50 d. In cattle slurry and river water, no E. colt O157:H7 was detected after 10 and 27 d, respectively (Maule 2000). Listeria monocytogenes The incidence and survival of L. monocytogenes has also been the focus of a few research studies. As part of a Listeria spp. survey in the United Kingdom, it was reported that 93.9% of 115 sewage samples were positive for Listeria, 20% of which were identified as L. monocylogenes. In garden soil, only 0.7% of the samples contained L. monocylogenes (MacGowan and others 1994). In an effort to know more about what environmental conditions or agricultural practices leading to the increase on produce contamination with L. morrocytogenes, a laboratory experiment with different soil types, inoculation levels, and fertilizer sources was conducted. Clay loam or sandy loam soil or soil amended with chicken manure resulted in higher survival of L. monocylogenes than sandy soil or soil fertilized with liquid hog manure or an inorganic fertilizer.Listeria monocytogenes levels slightly declined in clay soil and tended to increase in sandy loam soil, a discrepancy with other research showing L. monocytogenes declined to not detectable levels in 2 mo in sandy loam soil (Van Renterghem and others 1991) or 6 mo in clay soil (Welshimer 1960). Such discrepancies could be due to differing soil moisture levels. The authors however, concluded that there were no significant differences in L. monocytogenes populations in the tested soil types but field studies were needed to confirm these results (Dowe and others 1997). The organism has been found in soil in a frequency varying from 9 to 14% (Weis and Seeliger 1975). Using a variety of enrichment techniques,L. monocytogenes was detected in 16%and 20% of pig and cattle feces, respectively, but not detected in stored liquid manure or manured soil samples. In the fresh feces samples, L. monocylogenes died off after 3 wk and after 2 mo of storage if manure or soil was inoculated. Protozoa As mentioned previously, protozoa are also pathogens of concern and their survival in soil has been studied. The persistence of Giardia cysts and Cryptosporidium oocysts in water, cattle feces, and soil was investigated at-4, 4, and 25 °C (77 °F). One week of freezing and 2 wk at 25 °C (77°F) eliminated the infectivity of Giardia cysts. At 4 °C (39.2 °F)the infectivity remained for longer in water(11 wk), soil (7 wk), and feces (11 wk). Cryptosporidium cysts were more resistant, surviving in feces for up to 12 wk at 4 °C (39.2 °F). The results suggest that in order to minimize health risks from Cryptosporidium, contaminated feces should be distributed during warmer weather not earlier than 12 wk after storage. Otherwise an effective manure treatment needs to be performed (Olson and others 1999). A USDA study on Cryptosporidium parvum showed that vertical recovery of oocysts decreased rapidly in loam and sandy soils. Data from packed soil cores indicated that decomposition depends on the interactive effect of manure, soil structure, water flux, and time (USDA 1999). The number of oocysts in the leachate decreased exponentially on consecutive days after the application. In general, oocysts do not appear to be readily transported through tilled soils. Mother study monitored the potential for transfer of the pathogen Cryptosporidium parvum through soil to land drains and water courses after the application of livestock waste to land using simulated rainfall and intact soil cores. The authors reported that an initial load of 108 oocysts/core were reduced to undetectable or low numbers in lecheate after 21 d, depending on the soil type(Mawdsley and others 1996). 2.1.2.4. Timing and location factors All current guidance within organic and conventional agriculture strongly states that raw manure should not be applied directly to a field or immediately before harvesting an adjact;nt existing crop. Doing so may result in contact or indirect transfer to crops. This is most critical with produce typically eaten raw(for example, ala afy vegetables,herbs, soft twit, and melons). Spreading inappropriately aged manure nex to these crops should also be avoided, due to the potential for transmission of pathogens p_silust aerosols. Specific distance limits that would ensure the safety of the produce have not been scientifically validated. Predictive information on the persistence of key pathogens in aged, stacked dairy and cattle manure, a common handling method, is generally lacking. Limited time- temperature studies of Salmonella and E. coil survival in stacked piles support the effectiveness of current managed composting practices. Natural or artificially inoculated manure exposed to a temperature range of 45 to 50 °C (122 °F) eliminates detectable populations of these pathogens in less than 3 wk. Current practices are targeted to exceed this limit. The absolute window of time separation between the application of manure known to contain viable pathogens and safety of the harvested crop has not been sufficiently researched to account for all production, environmental, and crop-specific variables. Manure is predominantly applied to orchard floors or vegetable production ground in the fall, prior to leafing-out, bloom, seeding or transplanting. Rates and frequency of application vary widely but typically range from 4 to 6 tons/acre. Small-scale intensive, vegetable operations may apply the equivalent of as much as 12 to 14 tons/acre. Crops commonly produced in these systems, including many of the specialty greens, often have a short-rotation between seeding and harvest. In some areas, climatic conditions permit production well within the recommended temporal separation between aged manure incorporation and planting of 60 d. Some current recommendations or buyer specifications extend this period in excess of 100 d, effectively establishing this practice for growers in many marketing outlets. To the best of our knowledge, neither of these recommendations (60 or 100 d of temporal separation)has been evaluated, and currently there is no scientifically based determination of a safe temporal separation between aged manure incorporation and planting. Although placing field-stored piles next to existing crops is not a common practice, surviving populations in such piles represent an undetermined risk. Current experimental models predict that once E. coli O157:H7 is incorporated into soil, 99% of viable populations is lost in a period of 60 to 120 d depending on soil type, matric potential and other factors yet to be determined(Himathongkham, Bahari and others 1999). In parallel field studies over a two-year period,generic E. coli was not detectable during the planting season following soil incorporation of manure (E. coli was detectable at the time of incorporation) during the fall in coastal California vegetable fields (R. Smith, K. Schulbach, and T. Suslow; unpublished data; unreferenced). Within the limits of the sampling and detection methodology, no E. coli was detectable in 20 soils and the associated leafy vegetable crops and mesculun mix from these fields at the time of harvest. These preliminary data are consistent with the outcome of proprietary product testing being conducted by individual shippers and packaged salad processors. A handful of laboratory studies have addressed the fertilization with manure as a source of L. monocytogenes produce contamination. In a laboratory experiment performed in Iraq, when sewage cake contaminated with L. monocytogenes (3-15 cells/g)was added to soil, 10% of the alfalfa crop was positive for the pathogen, although levels were low (<5 cells/g) (Al-Ghazali and Al-Azawi 1990). Similarly, some of the parsley samples growing in pots with the same fertilizer was positive for the pathogen after 3 wk of fertilizer application. These researchers concluded that L. monocytogenes seems to be incapable of surviving for long periods in soil or liquid manure, which therefore cannot be considered reservoirs. A more likely reservoir is the plant-soil rhizosphere, since 50% of the radishes contained L. monocytogenes, but only 17% of soil samples in which radishes had been growing contained the pathogen. Listeria monocytogenes was detected in radishes sown in inoculated soil (50% of samples)but was not found in carrots (Van Reterghem and others 1991). The potential for growth, however, exists when produce is subjected to refrigeration temperatures, In conclusion, detailed, systematic, and large-scale testing of environmental fates of pathogens incorporated into soil and onto plant surfaces, within a controlled research facility, would be highly desirable. 2.1.3. Indirect contamination During production, and in some harvest and post-harvest situations, agricultural water may be contaminated by pathogen-containing manure or compost. At this time, animal waste management specialists generally recommend a 200 feet separation of untreated manure from wells, although less distance may be sufficient. At least 100 feet separation for sandy soil and 200 feet separation for loamy or clay soil (slope less than 6%;increase distance to 300 feet if slope greater than 6%) is recommended as distance between untreated manure and surface water. 2.1.4. Use of compost and manure-teas in organic produce Organic producers, based on philosophical preference and conviction or in response to an increasing market opportunity, exclude or prohibit the use of conventional crop inputs common to modern farming. Synthetic pesticides and fertilizers are not allowable in current organic certification programs. To achieve optimal quality and economic returns, organic farming systems rely upon crop rotations, crop residues, animal manures, legumes, green manures, off-farm organic wastes, mechanical cultivation, mineral- bearing rock powders, and biological pest control (UC 2000a,b,c,d,e,f). These components maintain soil productivity and tilths, supply plant nutrients, and help to control insects, weeds, and other pests. Plant disease control is a common objective of foliar treatments. Compost teas and liquid manures have been evaluated for their efficacy in the control of foliar diseases. Liquid manures are applied to establish and support biologically diverse and metabolically dynamic processes during production and extending to long-term land stewardship. The various liquid treatments are intended to serve, primarily, as a source of soluble plant nutrients, growth stimulants, and disease suppressors. Foliar-applied biotic extracts are believed to initiate a systemic response known as induced resistance, which may act as a repellant or reduce the severity of pest and disease activities on plants (Weltzien 1990). Various manure and compost extracts, such as horse, cattle, dairy and chicken, rabbit, goat, ostrich, and others alone or in combination with straw, cull vegetables, and other plant-based materials are reported to enable biologically based control of plant pathogens through their action on the phyllosphere (generally encompassing the leaf surface and associated foliar structures) (Blakeman 1981; Andrews and Hirano 1991; Suslow 2001 and references therein). A wide range of mechanisms including induced resistance(as mentioned above), delay or abortion of spore germination, other modes of antagonism, and nutrient and niche competition with pathogens contribute to the suppressive effects reported (Tranker 1992; Cronin and others 1996; Elad and Shtienberg 1994). In the context of addressing potential sources of fresh produce microbial contamination, the practice of applying manure slurries or teas to existing crops deserves special attention. As mentioned above, manure-enriched brews of various composition have been used by growers and home gardeners around the world for many years for fertility management and plant disease control. Domestically, the extent of use on fresh vegetables is unclear but the practice is popular among smaller-scale organic and biointensive producers. At this time, the numerous sources of instructional information on manure tea preparation and use are essentially devoid of any precautionary statements regarding human food safety. Typical preparation calls for the use of raw or aged manure in a 55-gallon drum (1:4 manure to water). After 2 to 3 wk, a strained tea or slurry is applied to soil or sprayed on foliage. The strained solids are applied to green waste compost piles. Himathongkham, Bahari and others (1999), Himathongkham, Nuanualsuwan and others (1999), and Himathongkham and others (2000) have determined a period of at least 10 d to greater than 70 d for the destruction of E. coli 0157:H7 and Salmonella Typhimurium in liquid manure slurries held at temperatures between 4 and 20 °C (39.2-68 °F). Extrapolation from recent research reports strongly suggests that mixing other organic components (generally plant origin) into the steeping drum water may increase the survival potential of E. coli 0157:H7 (Hancock and others 1997, Buckho and others 2000; McGee and others 2001) . Other potential pathogens and parasites, such as C.parvum, a serious water-borne pathogen, may survive the incubation period for manure tea. As manure teas are not uncommon in some regions, particularly for herb production(including fresh consumed)a greater effort at risk assessment of this practice is well justified. 2.1.5. Current research Clearly, the climate, soil properties, site characteristics and management practices (run- off,buffer strips, and water collection ponds) at a land application site will strongly influence the fate and transport of manure and any accompanying microbes. The details and dynamics of these processes are the subject of an international research effort at present. Examples of recent published reports include transport of pathogens in run-off from soil (Abu-Ashour and Lee 2000); environmental survival in soil (Barwick and others 2000; Maule 2000); survival in manure slurries(McGee and others 2001); fecal shedding of pathogens and environmental and vector dissemination (Buchko and others 2000; Wesley and others 2000; Jeffrey and others 2001); and composting and biosolids process improvements (Chauret and others 1999). Manure treatments that reduce the pathogen populations prior to and in conjunction with land application are increasingly being implemented and improved. Composting is one approach among many already in use and under scientific validation and optimization. Treatment technologies prior to land application are also the focus of an on-going effort by a USDA/ARS program on manure and byproduct utilization with the objective of developing a guide to pathogen reduction practices. Current agronomic practices and recommendations for use of animal manures in cropping systems are being revised in many states to reflect the need for protection of water quality (see section 2.2.). These efforts, though, focus primarily on nutrient management and groundwater contamination by chemical constituents, and the emphasis on pathogen ty management is limited. There is however, considerable awareness and discussion within the animal industry and among fresh fruit and vegetable producers, processors, and buyers retarding the potential for contamination of produce by_pathogens in manure. This increased awareness is due to the guidance and education documents developed by industry associations, that is, Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables (FDA 1998), and to the academic and extension activities regarding a shared commitment to improving microbial food safety. From IFT Task Order 3: http://www.cfsan.fda.gov/—comm/ift3-2a.hnnl Chapter II.Production Practices as Risk Factors in Microbial Food Safety of Fresh and Fresh-Cut Produce. Suslow, Trevor, M. Oria, L. Beuchat, E. Garret, M. Parish, L. Harris,J. Farber, and F. Busta Environmental Assessment Evaluation Prepared for: AGPROfessionals, LLC 4311 Highway 66 Suite 4 Longmont, CO 80504 March 2, 2004 Michael A. Veenhuizen, Ph.D. President Livestock Engineering Solutions, Inc. Greenwood, IN 46143 j EXHIBIT — y/ 1 Summary The purpose of this report is to summarize potential environmental factors and the potential impact of a livestock truck wash facility with a liquid/solids separator and wastewater lagoon on an existing nearby onion storage building. The wash water and manure solids generated from the livestock truck wash will be processed through a liquid/solid separator to remove the solids from the wash water. The separated solids are planned to be collected in a transport vehicle and regularly removed from the site. The processed wash water will be collected in a wastewater lagoon and land applied on nearby agricultural crop production ground with sprinkler irrigation. Questions have been raised regarding the impact of the manure and wash water handling on air emissions, odor, humidity, and pathogen transport. Air Emissions Air emissions and odors can result from the biological breakdown of organic materials such as manure solids generated from the truck wash. Potential emissions and odors that result from the biological breakdown of organic materials depend on the residence time, concentration, and treatment volume of a storage. Wastewater treatment/storage ponds are used to stabilize manure by taking advantage of natural biological processes. Advantages of wastewater treatment/storage ponds similar to the pond proposed as part of the truck wash include: • High degree of stabilization • High dilution rate for reduced odor emissions • Lower land application odors The performance of the wastewater treatment/storage pond is enhanced by the pretreatment liquid/solid separation process. The double-screen separator prior to the wastewater pond will typically remove 95% of the suspended solids and 55% of the total solids from the wash water prior to being stored in the wastewater pond. Advantages associated with the solids separation include: • Improved treatment efficiency of the treatment/storage pond. • Liquids can be reused to flush and pre-wash trucks, conserving water. • Reduce the volume of wash water to be land applied. Based on the planned capacity of the truck wash up to 15 truck per day will be washed out using 3,000 gallons per truck. This would generate approximately 45,000 gallons of wash water per day. During appropriate conditions the wash 2 water is planned to be land applied daily limiting the residence time available for biological breakdown and potential emission release. A key part of the wash water treatment/storage pond is to control the biological loading rate and enhance the treatment capabilities of the dilute wash water stored in the pond. To accommodate for changing weather conditions, land availability and other conditions, at least 30-days of storage capacity is planned to be maintained at all times. A 30-day storage volume for this truck wash is about 1,350,000 gallons. This storage capacity provides for a treatment pond that will further stabilize the wash water and control potential odor emissions. The effectiveness of a biological treatment system is dependent on the organic loading rate. The liquid/solid separator will remove between 55% and 95% of the biodegradable solids prior to wash water being stored in the pond. Based on the capacity of the truck wash and estimated volume of manure solids to be recovered from the truck wash, it is estimated that the manure solids recovered from the truck wash would be about 25% of the daily manure production for the number of animals transported by the trucks. Based on the minimum solids removal efficiency of the screen separator, no more than 45% of the biological solids will be loaded into the wash water treatment/storage pond. The Natural Resource Conservation Service has established design loading rates for treatment/storage ponds. Based on the Agricultural Waste Management Field Handbook (NRCS, Chapter 10) a biological loading rate of approximately 4.75 lb VS per 1,000 cubic feet is recommended for adequate biological treatment. Based on the predicted volume of manure generated from the truck wash each day the expected loading rate to the wash water treatment/storage lagoon is about 2.15 lb VS per 1,000 cubic feet. The Natural Resource Conservation Service Agricultural Waste Management Field Handbook design recommendation for loading rates to control odor is "Loading rates should be reduced approximately • 50% where odors must be minimized." The predicted loading rate for the wash water pond is about 45% of the design biological treatment loading rate recommended by the Natural Resource Conservation Service. The proposed wash water treatment/storage pond is sized to minimize odors and should not be a source of significant odor emissions to the local area. Odor emissions from the land application of the stored wash water will be minimized due to the pretreatment by removing the solids and treatment in the treatment/storage pond to stabilize the wash water. The expected odor emissions during land application will be greatly minimized by the handling and treatment of the wash water. Since the loading rates to the storage pond are less than the recommended loading rates to control odors and the wash water is not planned to be stored for long periods of time the potential for odor emissions from land application are minimized and should not have a negative or detrimental affect on the local area. 3 Humidity Humidity is a measure of the water-vapor mixture. An open water surface has the potential to add water to the air through evaporation. The impact of a small basin (224' x 489' surface area) on the humidity of the air is small to undetectable. For the purpose of comparison, it was assumed that the basin liquid surface was 224' x 489'. The typical surface area will be less than 224' x 489'. The amount of evaporation from a liquid surface is less during the cooler winter-spring months (November—April) than the warmer summer-fall months (May — October). The percent of annual evaporation from a liquid surface during the warmer months is about 72% (MWPS-18). The percent of annual evaporation from a liquid surface during the cooler months is about 28% (MWPS-18). Assuming an annual evaporation rate of 44" —48", approximately 0.19 in/day of evaporation would occur during the warmer months and 0.07 in/day of evaporation would occur during the cooler months. The evaporated water vapor will be carried away by the ambient air surrounding the area. To estimate the potential change in humidity, a conservative estimate is determined based on an air volume that is twenty feet high and the width of the assumed liquid surface (489feet). This assumptions would require that the air volume be confined to a finite area which typically does not occur in natural conditions. To estimate the volume of air to pass over the liquid surface a one (1) mph and five (5) mph wind speed is assumed. The original air temperature and humidity are assumed to be 40 F and 30% relative humidity. Based on these assumptions, the predicted amount of water vapor added to the air during the warmer months and a slight breeze condition (5 mph) may increase the relative humidity about 0.5% above the original relative humidity of 30%. During the warmer months and still air conditions (1 mph) the relative humidity may increase up to 3% above the original relative humidity of 30%. Based on the same assumptions, the predicted amount of water vapor added during the cooler months and a slight breeze condition (5 mph) may increase the relative humidity about 0.2% above the original relative humidity of 30%. During still air conditions and cooler months the relative humidity may increase up to 1.2% above the original relative humidity. These potential increases in relative humidity will not have any negative impact on the ventilation cooling and moisture control capabilities of ventilation equipment located near the storage basin. 4 Pathogen transport Bacterial and pathogen transport around agricultural production facilities is typically due to either particulate or aerosol transport. Potential bacteria or pathogen are either attached to the particulate or the aerosol droplet. Particulate transport from the truck wash as a part of the washing, wash water collection and transfer, wash water storage, and land application is not anticipated. Aerosol transport is a function of a mist or water droplet being created and carried by wind or air currents. The storage pond is not planned to be mixed, stirred, or aerated which could increase the potential for aerosol generation. Wave action due to high wind speeds may be a possibility under certain conditions, but is not anticipated to be a frequent occurrence. Any water droplets or aerosol created by the affect of wind currents on the water surface would be large diameter water droplets and would most likely not be carried more than about fifty (50) feet from the edge of the storage pond. The dilute nature of the wash water and the treatment process of holding and storing the wash water reducing the potential concentration of bacteria in the wash water compared to undiluted manure. In addition, the handling of the wash water in the storage pond does not require the surface to be stirred or agitated, which could increase the potential for aerosols to be generated. The risk of bacteria and/or pathogen transport from the storage pond to the local area is minimized by the treatment characteristics of the storage pond and the planned handling, collection, and transfer activities that do not involve agitation of the liquid surface. The planned land application method associated with the truck wash has been indicated to include sprinkler irrigation on agricultural production ground typically supporting plant growth. A low pressure irrigation method with drop nozzles is planned to reduce the potential for aerosol drift. Low pressure, low trajectory or drop nozzle irrigation equipment reduce the potential for aerosol drift or transport from the land application site. The combination of the irrigation equipment, separation distance between the land application areas and surrounding storage structures, and the dilute, stabilized characteristics of the wash water control and minimize the potential for bacteria or pathogen transport from the land application site. The risk of pathogen transport to surrounding areas and adjacent storage structures is minimal considering the practices implemented to land apply the wash water. Insects The prevention of insect problems is important for all agriculturally related sites. Good sanitation is the primary basis of all fly-control programs. A sanitation 5 program and manure solids removal schedule to interrupt and prevent fly breeding is desired. The regular removal of the separated manure solids from the truck wash interrupts and prevents breeding areas associated with the manure solids (Ohio Livestock Manure and Wastewater Guide). Fly breeding locations typically require solids to lay eggs, such as crust. The dilute nature of the wash water in the storage pond reduces the potential for suitable fly breeding and egg laying sites to exist. The frequent removal of wash water from the basin also helps to interrupt any potential fly breeding sites. A review of an aerial photograph indicates the existence of cattle feedlots in close proximity to the truck wash site. It is anticipated that these cattle feedlots may have a greater impact on the potential fly and insect population in the area than the activities associated with the truck wash due to the regular removal of manure solids and wash water from the truck wash. Conclusions • It is unlikely that the livestock truck wash will have a significant impact or contribution of odors or emissions to the local area and adjacent storage building. • It is unlikely that the livestock truck wash will result in the transmission or transport of bacteria or pathogens as a result of the truck wash operation to the local area. • It is unlikely that the land application of wash water from the truck wash storage pond will result in the transport of bacteria or pathogen to the local area. • The typical Colorado dry climate promotes the ability to control moisture build-up and humidity through the effective use of ventilation air. It is unlikely that the location and operation of the truck wash and storage pond will affect the humidity of the air in and around the truck wash. • It is unlikely that the truck wash will negatively impact the ventilation and environmental control function of the adjacent storage building. • It is unlikely that the truck wash will result in any change in the potential insect population in the area surrounding the truck wash and adjacent storage building. References Koelsch, R. "Planning and Managing for Odor Control." Liquid Manure Application Systems: Desiqn, Management, and Environmental Assessment, NRAES-79. Ithaca, New York. Northeast Regional Agricultural Engineering Service. 1995. Midwest Plan Service. Livestock Waste Facilities Handbook. Ames, Iowa. Iowa State University. 1985. 6 Midwest Plan Service. Manure Storages. Ames, Iowa. Iowa State University. 2001. Natural Resource Conservation Service. Agricultural Waste Management Field Handbook. United States Department of Agriculture. Washington, D.C. 1992 Veenhuizen, M.A. Ohio Livestock Manure and Wastewater Management Guide. Ohio State University. 1992. 7 r' Michael A. Veenhuizen Livestock Engineering Solutions, Inc. 2925 South Honey Creek Road Greenwood, Indiana 46143 (317) 535-1829 VOICE (317) 535-9806 FAX may@iquest.net E-MAIL • EDUCATION: Ph.D. 1989 Agricultural Engineering Indoor/Outdoor Air Quality Iowa State University and Control Ames, Iowa M.S.A.E. 1982 Agricultural Engineering Agricultural Waste Management, Purdue University Treatment, and Control West Lafayette, Indiana B.S.A.E. 1980 Agricultural Engineering Structures and Environment Purdue University West Lafayette, Indiana PROFESSIONAL ASSOCIATIONS: American Society of Agricultural Engineers (ASAE) Professional Engineers Institute (PEI) American Concrete Institute (ACI) AREAS OF SPECIALIZATION: Indoor and Outdoor Air Quality Manure and Agricultural Waste Management Manure and Process Wastewater Treatment and Control Livestock Facility Planning and Design Ventilation and Environmental Control Agricultural Structures PROFESSIONAL EXPERIENCE: Engineering Consultant/ Livestock Engineering Solutions, Inc. 1994 - present President Greenwood, Indiana Assistant Professor/ Department of Agricultural Engineering 1989 - 1994 Extension Agricultural Engineer The Ohio State University Plan Service Engineer Midwest Plan Service 1982 - 1989 Department of Agricultural Engineering Iowa State University a. EXHIBIT SW PROFESSIONAL ASSOCIATIONS, ACTIVITES,AND COMMITTEES USDA National Task Force on Waste Storage Covers Natural Resource Conservation Service Technical Feasibility Committee: 2002 USDA National Task Force on Agricultural Air Quality Natural Resource Conservation Service Member: 1996-1998 Representing commodity groups and agricultural production National Pork Producers Council (NPPC) Environmental Assessment Program National Environmental Assessment Program Instructor and Trainer— 1995-1998 National Pork Producers Council (NPPC) On-Farm Odor and Environmental Assessment Steering and Development Committee: 1996-1997 National On-Farm Odor and Environmental Assessment Trainer: 1997-2000 On-Farm Odor and Environmental Assessment Inspector/Evaluator: 1997-2001 American Society of Agricultural Engineers Member: 1980-2003 Professional Engineers Institute— 1995-2003 Vice-Chair—2002-2004 Dairy Housing Committee (SE-403) -- 1990-1996 Swine Housing Committee (SE-404) -- 1988-2001 Structures Group (SE-20) -- 1990-1994 American Concrete Institute Member: 1997-2003 PUBLICATIONS, PAPERS, AND ARTICLES a. Books B.J. Holmes, A.J. Heber, D.D. Jones, G.L. Riskowski, M.A. Veenhuizen, K.A. Janni, J.P. Murphy. R.E. Graves, R.E. Phillips. Mechanical Ventilating Systems for Livestock Housing, MWPS-32, 1990. Midwest Plan Service. Ames, IA. 70 pages. B.J. Holmes, W.G. Bickert, M.F. Brugger, D.D. Jones, L.D. Jacobson, M.A. Veenhuizen, G.L. Riskowski, R.E Graves, A.J. Heber, and J.P. Murphy. Natural Ventilating Systems for Livestock Housing, MWPS-33, 1989. Midwest Plan Service. Ames, IA. 31 pages. B.J. Holmes, J.A. DeShazer, A.J. Heber, L.D. Jacobson, K.A. Janni, D.D. Jones, M.A. Veenhuizen, G.L. Riskowski, and M.F. Brugger. Heating, Cooling, and Tempering of Air for Livestock Housing, MWPS-34. 1991. Midwest Plan Service. Ames, IA. 47 pages. Structures and Environment Handbook, revision, MWPS-1, 1987. Midwest Plan Service. Ames, IA. 600 pages. W.G. Bickert, M.F. Brugger, G.R. Bodman, D. Kammel, M.A. Veenhuizen, and J. Chastain. Dairy Freestall Housing and Equipment Handbook, MWPS-7, 1995. Midwest Plan Service. Ames, IA. 120 pages. b. Bulletins Mancl, K.M., J. Johnson, and M.A. Veenhuizen. Septage Management in Ohio, Extension Bulletin 854. 1995. Ohio Cooperative Extension Service. Columbus, OH. 26 pages. Mescher, T.M. and M.A. Veenhuizen. Livestock Housing Ventilation: Natural Ventilation Design and Management for Dairy Housing. 1995. Ohio State University Extension Fact Sheet AEX-113. Columbus, Ohio. 4 pages. Veenhuizen, M.A. and Timothy Lawrence. Liquid Manure Storage Safety. 1994. Ohio State University Extension Fact Sheet AEX-392-94. Columbus, Ohio. 4 pages. Arnold, G.J. and M.A. Veenhuizen. Livestock Housing Ventilation: Air Inlet Designs and Management. 1994. Ohio State University Extension Fact Sheet AEX-110-94. Columbus, Ohio. 3 pages. Arnold, G.J. and M.A. Veenhuizen. Livestock Housing Ventilation: Fan Performance and Management. 1994. Ohio State University Extension Fact Sheet AEX-111-94. Columbus, Ohio. 3 pages. Arnold, G.J. and M.A. Veenhuizen. Livestock Housing Ventilation: Fan Selection. 1994. Ohio State University Extension Fact Sheet AEX-112-94. Columbus, Ohio. 3 pages. Mancl, K.M. and M.A. Veenhuizen. Avoiding Stream Pollution from Animal Manure. 1994. Ohio Cooperative Extension Service Fact Sheet AEX 708. Columbus, Ohio. 4 pages. Veenhuizen, M.A. and K.M. Mancl. Land Application Of Livestock Waste...Legislation, Regulations, Guidelines, and Standards. 1993. Ohio Cooperative Extension Service Fact Sheet AEX 710. Columbus, Ohio. 2 pages. Veenhuizen, M.A. and H.E. Ozkan. On-Farm Agrichemical Mixing/Load Pad. 1993. Ohio State University Extension Fact Sheet AEX-522. Columbus, Ohio. 4 pages. Veenhuizen, M.A., D.J. Eckert, K. Elder, J. Johnson, W.F. Lyon, K.M. Mancl. and G. Schnitkey. Ohio Livestock Manure & Wastewater Management Guide, Extension Bulletin 604. 1992. Ohio Cooperative Extension Service. Columbus, OH. 79 pages. Mancl, K.M. and M.A. Veenhuizen. Managing Livestock Waste Facilities-- Controlling Crystal Formation in Recycle Flush Systems. 1992. Ohio Cooperative Extension Service Fact Sheet AEX 709. Columbus, Ohio. 4 pages. c. Journal Articles Mancl, K.M., M.A. Veenhuizen, and M Watson. Educating County Extension Agents in Waste Management. 1996. Applied Engineering Journal in Agriculture. American Society of Agricultural Engineers. St. Joseph, MI. Vol 12(4):501-507. Veenhuizen, M.A. and K.M. Mancl. Educating County Agents About Mechanical Ventilation. 1994. Applied Engineering Journal in Agriculture American Society of Agricultural Engineers. St. Joseph, MI. �.. Gerber, D.B., K.M. Mancl, M.A. Veenhuizen, G.C. Shurson. Ammonia, Carbon Monoxide, Carbon Dioxide. Hydrogen Sulfide, and Methane in Swine Confinement Facilities. 1991. Compendium on Continuing Education for the Practicing Veterinarian. Vol 13(9). September 1991. pp. 1483-1489. d. Proceedings Veenhuizen, M.A. Changes in the Wind: New Environmental and Odor Regulations. 1999. Swine Environmental Field Tour '99, Renville County, Minnesota. University of Minnesota. Minneapolis-St. Paul, MN. 4 pages. Veenhuizen, M.A. Siting Decisions in Modern Pork Production: How to Minimize Community Concerns. 1998. Societal Issues in Pork Production, Workshop#11. 29th Annual Meeting American Association of Swine Practitioners. Pp. 15-23. Veenhuizen, M.A. Proper Odor Management on Your Farm and Producer Responsibilities and Benefits: Odor Control for the Pork Industry. 1998. On-Farm Odor/Environmental Assistance Program, A satellite conference for pork producers. National Pork Producers Council, Pork '98. Des Moines, IA. 15 pages. Veenhuizen, M.A., and L. Meador. On-Farm Odor/Environment Assessment. 1998. On- Farm Odor/Environmental Assistance Program, a satellite conference for pork producers. National Pork Producers Council, Pork '98. Des Moines, IA. 2 pages. Veenhuizen, M.A., and L. Meador. Managing Pork Production Systems, Environmental Awareness and Responsibility. 1998. On-Farm Odor/Environmental Assistance Program, a satellite conference for pork producers. National Pork Producers Council. Pork '98. Des Moines, IA. 4 pages. Veenhuizen, M.A. Managing Confined Feeding Operations: Legislation, Regulations, and Guidelines. 1998. Indiana Veterinary Medical Association Annual Meeting. Indiana Veterinary Medical Association. Indianapolis, IN. 7 pages. Veenhuizen, M.A. Manure Management Practices: Not in My Baclryard! 1997. Waste Management: Public Concerns, Practical Approaches. University of Illinois College of Veterinary Medicine. Urbana, IL. 12 pages. Veenhuizen, M.A. Managing Existing Manure-Handling Systems. 1997. Waste Management: Public Concerns, Practical Approaches. University of Illinois College of Veterinary Medicine. Urbana, IL. 3 pages. Veenhuizen, M.A. Practical Control of Livestock Odors. 1997. Oklahoma State University Annual Waste Management Conference, Focus on Swine Production in the Panhandle Region. OSU, Oklahoma Cooperative Extension Service. Oklahoma Panhandle State University. Goodwell, OK. 13 pages. Veenhuizen, M.A. Odor-- An Environmental Challenge for the Pork Industry. 1996. Practical Solutions to Odor Problems, A satellite conference for pork producers. National Pork Producers Council, Pork '96, Pioneer. Des Moines, IA. 13 pages. Veenhuizen, M.A., L. Burkhalter, D. Nikodim, and J. Gabriel. Becoming An Environmental Assurance Program Certified Trainer. 1996. 1996 Swine Extension Educators Conference. National Pork Producers Council. Des Moines, IA. Veenhuizen, M.A. New Building Construction-- What To Look For. 1996. Pork Academy. National Pork Producers Council. Des Moines, IA. pp 126-141. Veenhuizen, M.A. Measurement of Air Quality in Swine Facilities. 1996. Fourth Annual Swine Disease Conference for Swine Practitioners. Iowa State University College of Veterinary Medicine. Iowa State University. Ames, IA. 7 pages. Veenhuizen, M.A. Common Sense Odor Solutions. 1995. Pork Academy. National Pork Producers Council. Des Moines, IA. pp 126-141. Veenhuizen, M.A. Building Design Features: Adapting to an Expanding Swine Industry. 1995. Pork Pro Talk. World Pork Expo. Des Moines, IA. pp 18-31. Veenhuizen, M.A. Practical Tips on Remodeling Existing Facilities. 1994. 1994-95 Swine Management Seminars. Elanco Animal Health/Brock Associates. Milwaukee, WI. Veenhuizen, M.A. Building Design Features: What Lies Ahead? 1994. Leaning Toward Gains In Productivity, Pork Pro Talk. World Pork Expo. Indianapolis, Indiana. Veenhuizen, M.A. My Ideas For The Perfect Building. 1994. Swine Facilities Workshop. University of Nebraska Cooperative Extension/Nebraska Pork Producers Association. University of Nebraska. Lincoln, NE. Veenhuizen, M.A. Ventilation More Than A Windy Day- Planning and Evaluating Ventilation Systems. 1994. Swine Facilities Workshop. University of Nebraska Cooperative Extension/Nebraska Pork Producers Association. University of Nebraska. Lincoln, NE. Veenhuizen, M.A. From Pig Sty to Pig Heaven- Existing Buildings--Remodel or Build New? 1994. Swine Facilities Workshop. University of Nebraska Cooperative Extension/Nebraska Pork Producers Association. University of Nebraska. Lincoln, NE. Veenhuizen, M.A. and K.M. Mancl. Ohio Experiences Related To Political And Social Issues of Animal Waste Management. 1993. Livestock Waste Management Conference. Minnesota Extension Service. St. Paul, MN. pp 133-138. Mancl, K.M. and M.A. Veenhuizen. Dealing With Waste Management And Related Issues-- A Perspective From Other Midwestern States. 1993. Livestock Waste Management Conference. Minnesota Extension Service: St. Paul, MN. pp 14-18. Veenhuizen, M.A. Swine Manure Management and the Environment. 1992. Proceedings of the MIATCO Mexico Swine Symposium. Mid-America International Agri-Trade Council. Chicago, IL. 12 pages. (translated into Spanish) Veenhuizen, M.A. Ohio's Manure Regulations and Guidelines. 1992. Proceedings of the 1992 Ohio State University Dairy College. Columbus, OH. Veenhuizen, M.A. Feeding System Design-- Feed Mangers and Barriers. 1991. Proceedings of the Ohio Dairy Feeding Conference. Wooster, OH. Veenhuizen, M.A. Sheep Housing, Ventilation, and Environment. 1991. Proceedings of the 1991 Indiana Producers Annual Conference. Indianapolis, IN. Veenhuizen, M.A. Manure Management. 1991. Proceedings of the 1991 Professional Pork Producers Symposium. Dayton, OH. Veenhuizen, M.A. Manure Management Update. 1991. Proceedings of the 107th Ohio Veterinary Medical Association Convention. Columbus, OH. Veenhuizen, M.A. Ventilation for Modern Dairy Facilities. 1991. Proceedings of the 1991 Indiana Farm Bureau Co-op Dairy Consultants Training Conference. Indianapolis, IN. Veenhuizen, M.A. Tunnel Ventilation of Livestock Buildings. 1991. Proceedings of the 1991 Indiana Farm Bureau Co-op Dairy Consultants Training Conference. Indianapolis, IN. Veenhuizen, M.A. Dust Control in Swine Buildings. 1990. Ohio Swine Research and Industry Report, Animal Science Department Series 90-1. Columbus, OH. Veenhuizen, M.A. Swine Manure Management. 1990. Ohio Swine Research and Industry Report, Animal Science Department Series 90-1. Columbus, OH. Veenhuizen, M.A. Latest Developments in Dust Control in Swine Buildings. 1990. Proceedings of the 1990 American Association of Swine Practitioners Annual Convention. Denver, CO. Veenhuizen, M.A. Swine Housing and Environment, Proper Design and Troubleshooting. 1990. Proceedings of the 106th Ohio Veterinary Medical Association Convention, Session 4420. Columbus, Ohio. Veenhuizen, M.A. Proper Dairy Ventilation for a Healthy Environment, Principles and Application. 1990 Proceedings of the 106th Ohio Veterinary Medical Association Convention, Session 2460, Columbus, OH. Veenhuizen, M.A. Providing a Healthy Environment with Proper Ventilation. 1990. Proceedings of the 1990 Ohio State University Dairy College, Controllingthe Environment for Efficient Milk Production. Columbus, Ohio. Veenhuizen, M.A. Solving Nursery and Farrowing Room Ventilation Problems. 1990. Ohio State University Swine Production Update Program. Columbus, OH. Veenhuizen, M.A. Existing Buildings- Remodel or Build New?. 1989. Proceedings of the 1989 Ohio State University Swine Technology Day. Columbus, OH. Veenhuizen, M.A. Remodeling Grower and Finisher Facilities- An Example. 1989. Proceedings of the 1989 Ohio State University Swine Technology Day. Columbus, OH. e. Technical Papers Mescher, T., T. Menke, M. Veenhuizen, H Keener, R. Stowell. Design, Performance, and Economics of High Rise Swine Finishing Buildings. 1999. ASAE Paper No. 99-4107. 1999 ASAE/CSAE-SCGR Annual International Meeting. American Society of Agricultural Engineers. St. Joseph, MI. Veenhuizen, M.A. Impact of Regulatory Compliance on Production Costs for Livestock Producers. 1998. 59°i Minnesota Nutrition Conference & IPC Technical Symposium. University of Minnesota Extension Service. Bloomington, MN. Pp. 175-186. Bender, Roger, R.R. Stowell. and Michael Veenhuizen. Natural Ventilation Alternatives for Two-Story Barns.. 1997. ASAE Livestock Environment V, Fifth International Symposium. Bloomington, MN. Pp. 743-747. Veenhuizen, M.A. and R. Graves. Convalescent and Maternity Facilities for Large Dairies. 1994. ASAE International Dairy Housing Conference III. Orlando, FL. Veenhuizen, M.A. and Rugang Qi. Manure Storage pH Adjustment to Control Gas Release. 1993. ASAE Paper No. 93-4552. 1993 International Winter Meeting of the American Society of Agricultural Engineers. American Society of Agricultural Engineers. St. Joseph, MI. Veenhuizen, M.A. and K.M. Mancl. In-service Curriculum in Ventilation for County Agents. 1992. ASAE Paper No. 92-5529. 1992 International Winter Meeting of the American Society of Agricultural Engineers. American Society of Agricultural Engineers. St. Joseph, MI. Veenhuizen, M.A. and Rugang Qi. Reducing Noxious Gas Emissions and Odors From Manure Storages. 1992. ASAE Paper No. 92-4073. 1992 International Summer Meeting of the American Society of Agricultural Engineers. American Society of Agricultural Engineers. St. Joseph, MI. Veenhuizen, M.A. and D.S. Bundy. Electrostatic Precipitation Dust Removal System for Swine Housing. 1990. ASAE Paper No. 90-4066. 1990 International Summer Meeting of the American Society of Agricultural Engineers. American Society of Agricultural Engineers. St. Joseph, MI. Veenhuizen, M.A. and D.S. Bundy, Development and Evaluation of Atmospheric Dust Removal System, ASAE Paper No. MC90-111, 1990 Mid-Central Conference of the American Society of Agricultural Engineers, March 1990. Bundy, D.S. and M.A. Veenhuizen. Dust and Bacteria Removal Equipment for Controlling Particulates in Swine Buildings. 1987. Latest Developments in Livestock Housing. Seminar of the 2nd Technical Section of the C.I.G.R. American Society of Agricultural Engineering. St. Joseph, MI. f. Design, Evaluation, and Application Manuals/Notebooks Veenhuizen, M.A., K.M. Mancl, M. Watson, T. Mescher, and R. Stowell. Waste Storage and Handling. 1996. Ohio State University Extension. Columbus, Ohio. Mancl, K.M., M.A. Veenhuizen, and M. Watson. Waste Treatment-- Manure, Sludge, and Septage. 1994. Ohio State University Extension. Columbus, Ohio. Veenhuizen, M.A. Heating, Cooling, and Tempering Air for Livestock Housing. 1993. Ohio State University Extension. Columbus, Ohio. Mancl, K.M., M. Watson, and M.A. Veenhuizen. Land Application of Waste. 1993. Ohio State University Extension. Columbus, Ohio. Veenhuizen, M.A. Natural Ventilation of Livestock Housing. 1992. Ohio State University Extension. Columbus, Ohio. Veenhuizen, M.A, K.M. Mancl, and M. Watson. Waste Storage and Handling. 1992. Ohio State University Extension. Columbus, Ohio. Veenhuizen, M.A. Mechanical Ventilation of Livestock Housing. 1991. Ohio State University Extension. Columbus, Ohio. Mancl, K.M., M.A. Veenhuizen, and M. Watson. Waste Treatment-- Manure, Sludge, and Septage. 1991. Ohio State University Extension. Columbus, Ohio. Mancl, K.M., M. Watson, and M.A. Veenhuizen. Land Application of Waste. 1990. Ohio State University Extension. Columbus, Ohio. g. Video Production National Pork Producers Council and Pork'98. "On-Farm Odor/Environmental Assistance Program, A satellite conference for pork producers." 1998. National Pork Producers Council. Des Moines, IA. �-. National Pork Producers Council, Pork '96, and Pioneer. "Practical Solutions to Odor Problems, A satellite conference for pork producers." 1996. National Pork Producers Council. Des Moines, IA. Veenhuizen, M.A. and G.J. Arnold. "Evaluating Livestock Building Environments for Improved Performance." 1994. Ohio State University Extension. Columbus. Ohio. AWARDS AND RECOGNITION 1999 Maxine Nash Memorial Pork Industry Promotion, Education, and Support Award. Indiana Pork Producers Association American Society of Agricultural Engineers (ASAE) Blue Ribbon Award for the following publications. 1994 "Pesticide and Agrichemical Mixing/Loading and Containment Pad." Veenhuizen, M.A. and H.E. Ozkan "Waste Management Training Manual and Curriculum-- 3-year program." Mancl, K.M. and M.A. Veenhuizen. 1992 "Ohio Livestock Manure and Wastewater Management Guide, OCES Bulletin 604." Veenhuizen, M.A., D.J. Eckert, K. Elder, J. Johnson, W.F. Lyon, K.M. Mancl, G. Schnitkey. 1991 "Heating, Cooling, and Air Tempering for Livestock Housing, MWPS-34." B.J. Holmes. J.A. DeShazer, A.J. Heber, L.D. Jacobson, K.A. Janni, D.D. Jones, M.A. Veenhuizen, G.L. Riskowski, and M.F. Brugger 1990 "Natural Ventilating Systems for Livestock Housing, MWPS-33." B.J. Holmes, W.G. Bickert, M.F. Brugger, D.D. Jones, L.D. Jacobson, M.A. Veenhuizen, G.L. Riskowski, R.E Graves, A.J. Heber, and J.P. Murphy Microbiological Consultation AGPROfessionals, LLC 4311 Highway 66 Suite 4 Longmont, CO 80504 March 1 , 2004 Cheryl D. McCall, REHS NFPA Certified Auditor Laboratory Manager/ Research Associate Colorado State University— Environmental Health Services Fort Collins, CO 80523-6021 EXHIBIT 1 Summary The purpose of this report is to provide a site evaluation and an impact statement of the effects of a livestock truck wash facility with wastewater lagoon on an existing nearby onion storage building. An initial visit to the site area (near the corner of Colorado Highway 263 and Weld County Road 49) was made on February 13, 2004, with an additional visit on February 18, 2004. Visits to an existing livestock truck wash facility and again to the site of the proposed facility were made on February 27, 2004; samples were collected at both sites. Background Information There are a variety of methods in which raw produce can be contaminated with bacteria, viruses, or parasites. The most common mode of contamination is use of dirty water for irrigation. Studies have shown that spray irrigation with dirty water is linked to contamination of crops, and suggest that repeated exposure increases the level of Escherichia coli 0157:H7 (human pathogen) on the plants.' Additional studies have shown that growing plants can take up bacterial contaminants and incorporate them into tissues inside the plant, where no sanitizer or method of cleaning can remove them. Contamination of field crops can also result from application of uncomposted manure, from bird or rodent droppings which fall into harvest bins, from contaminated trucks or equipment, from washing the produce with contaminated water, or from farm workers with unwashed hands or poor personal hygiene. Good Agricultural Practices (GAPs) were developed by the agricultural industry in conjunction with the Food and Drug Administration (FDA) and United States Agriculture Department (USDA). These are a series of recommendations for areas of concern. The 1998 FDA "Guidance for Industry--Guide to Minimize Microbial Food Safety Hazards for Fresh Fruits and Vegetables". This guide identifies eight principals of food safety concerning growing, harvesting, cleaning/washing, sorting, packing, and transporting of fresh produce. In this document, the FDA suggests that the recommendations be used to help a producer develop the most appropriate good agricultural and management practices for their operation. The document is meant to provide guidance, but has no regulatory or legal weight. The recommendations include common-sense techniques designed to minimize contamination of foods, including instruction on proper cleaning, maintenance, and storage of harvesting equipment, proper hand washing and personal hygiene techniques for field workers, and safe water storage and use.2 2 Most food borne diseases associated with fresh produce involve items that have undergone some type of minimal, non-thermal processing, followed by time and temperature conditions that permit pathogens to survive and grow. Normally, the exterior of produce acts as a physical barrier, preventing bacteria from penetrating to the interior. Once the surface barrier is broken, though, bacterial growth can take place. The onion bulb has outer layers that are not removed until just before use. These layers, unless cut or damaged, protect the onion from contamination. This means that any mechanical processing or rough handling of produce increases the risk of bacterial penetration and growth. While all care should be taken to avoid contamination of field crops, several issues must be considered. Any food crop grown in soil is assumed to be contaminated and must be handled and prepared for consumption with this fact in mind. Just as you should not pick a piece of fruit from a tree and eat it without washing, onions, carrots, and root crops must be washed (in addition to peeling for many items). At this time, I am unaware of any food borne illness outbreaks due to consumption of contaminated onions, other than the 2003 Hepatitis A (viral) outbreaks involving contaminated green onions. In these outbreaks, it is thought that the onions were contaminated by contact with Hepatitis A-infected field workers or by contact with Hepatitis A-contaminated water during irrigation, rinsing, or processing. 3 I am not aware of any outbreaks associated with white or yellow onions, probably due to the fact that they are handled with skins intact. As far as Campylobacter bacterial food borne infections, the majority are associated with poultry. Campylobacterjejuni, and less commonly, Campylobacter colt, are the usual causes of Campylobacter diarrhea in humans. Reservoirs are poultry, cattle, puppies, kittens, other pets, swine, sheep, rodents, and birds. These organisms are involved in illness in all parts of the world and in all age groups. Illness usually lasts for 2-5 days, and is susceptible to antibiotic treatment. Infected persons develop lasting immunity. Common source outbreaks are most often associated with undercooked chicken, unpasteurized milk, and non-chlorinated water. Most raw poultry meat is contaminated with C. jejuni. Modes of transmission include: ingestion of the organisms in undercooked chicken, pork, or other contaminated foods; drinking of contaminated water or raw milk; contact with infected pets (especially puppies and kittens), farm animals, or infected infants. Cross-contamination (such as ready-to eat foods in contact with juices from raw poultry on a kitchen cutting board) is a common method of transmission. Person-to-person transmission is rare.4 I am not aware of any food borne illness outbreaks due to contamination of raw produce with Campylobacter other than those due to either cross- contamination (raw meat) or from failure to wash (or use of contaminated water to wash) the produce. Onion bulbs are one of the world's oldest cultivated vegetables and are widely used for culinary purposes. They have antifungal and anti-bacterial properties 3 (due to the sulfur compounds they contain), but are usually consumed for their flavor. Several studies have demonstrated that harvest maturity has the greatest influence upon storability of onions. There is a close relationship between harvesting and drying management and the success of long-term storage of onions. Onion maturity, known to influence storage potential, also appears to affect post harvest shelf-life. Investigations have suggested that the primary cause of translucent scales (poor quality) is an improper internal atmosphere inside the onion, with high carbon dioxide and low oxygen levels. Post harvest problems, such as sprouting and bacterial or fungal rots, appear to be related more to harvest time (too late), temperature (too high), and drying time (too long).5.6 The condition of the onion at harvest time is critical in relation to disease infestation and stage of disease development. In addition, onion type influences susceptibility to disease and decay. Sweet onions are not as pungent, and thus do not possess the sulfur compounds that provide protection from infection by pathogens that may enter the onion bulb through openings in the neck or incisions.' As to any possible problems with onion absorbing odor from the truck wash operation, there is no evidence to suggest that an outside odor affects the flavor development inside an onion. Onion flavor is dominated by a special class of biologically active organic-sulfur compounds. Intact dry-bulb onions have little onion flavor or aroma. Flavor and aroma develop only when the onion is cut or damaged. This activates flavor precursor compounds which undergo enzymatic decomposition to form volatile sulfur compounds (which give onions their characteristic taste and aroma). Specific onion variety flavor is determined by plant genetics and the environmental conditions in which the onion grows (sulfate availability, growing temperature, and water supply).8 In light of the fact that there is an existing odor problem present at the site, it does not seem probable for this to be an issue. Site Observations Date: Feb. 13, 2004 Visit to Site Weather: mostly sunny Air temperature: 40.9 degrees F. Relative Humidity: 30.1% Wind: very light breeze (5 mph) from the northwest In spite of the fact that the livestock truck wash facility has not yet been installed, there was an obvious unpleasant odor present at the site. This is most likely due to the proximity of several large livestock operations (farms and feedlots within 0.3 mile of the site). Another possible cause, considering the prevailing wind direction at the time of the visit, might have been odor from an existing Greeley beef processing facility, 4 The onion storage building is located approximately 200 feet from Colorado Hwy. 263. The area around the building is unpaved, with weeds growing immediately adjacent to the building. Additionally, various sections of metal pipe, wooden boxes, and wooden pallets are stored a short distance from the building. The existing irrigation pond to the northwest of the building is separated from the onion storage property by several piles of soil and concrete debris. The appearance of properties in the near vicinity is consistent with those of an industrial park, not pristine agricultural areas. Date: Feb. 18, 2004 Visit to Site and Nearby Areas Weather: Partly cloudy Air temperature: 55.7 degrees F. Relative Humidity: 39.9% Wind: light breeze (5 mph) from the southeast At the time of this site visit, there also was evidence of a very strong, unpleasant odor, most likely from adjacent feedlots. Air samples were collected using a calibrated "pbi Air Sampler, SAS-Super 100" model. This instrument uses a measured amount of air (time and volume) pulled through a sanitized metal plate with holes. Bacteria or molds are then captured on the plates, which are taken to the laboratory and incubated at the appropriate time and temperature (depending on the type of media used). Three types of media plates were used in the air sampler: Violet Red Bile Agar with MUG (used to detect coliform bacteria and E. coh), Malt Extract Agar (for molds), and Plate Count Agar (for general bacterial growth. All media used is Difco brand, prepared at the Colorado State University Environmental Quality Laboratory, Environmental Health Services Department. Quality assurance records for laboratory practices and media preparation are available at the lab. Following incubation, colonies on the surface of the plates were counted. The number of organisms counted was corrected to account for the statistical probability of multiple particles passing through the same hole. Results (corrected counts in colony-forming units per cubic meter of air sampled, average counts from 2 plates) are as follows: Site 1. NW of onion storage building, near irrigation pond Results: Coliforms: <10, Bacteria: 370, Molds: 960 Site 2. NW corner of onion storage property Results: Coliforms: <10, Bacteria: 220, Molds: 210 Site 3. SE corner of onion storage property Results: Coliforms: <10, Bacteria: 1520, Molds: 930 Site 4. Bliss Industrial Site 5 Results: Coliforms: <10, Bacteria: 740, Molds: 240 Site 5. Feedlot, 15 feet from manure pile Results: Coliforms: <10, Bacteria: 400, Molds: 230 Date: Feb. 27, 2004 Visit to Existing Livestock Truck Wash Facility Weather: Cloudy Air temperature: 58.3 degrees F. Relative Humidity: 22.1% Wind: 8-12 mph from the east-southeast Time: 1045 Little unpleasant odor was noticed from the truck wash area or the collection pond itself. There was an odor present from the adjacent livestock feedlot. Air samples were collected using a calibrated "pbi Air Sampler, SAS-Super 100" model, using same procedures as described above. Site 1. 10 feet from livestock truck during wash down (truck had just delivered load of cattle to Swift Processing Plant) Results: Coliforms: 10 ( E.coli: 10), Bacteria: 390 Site 2. 30 feet from livestock truck during wash down Results: Coliforms: <10, Bacteria: 260 Site 3: 30 feet from wash down area, 5 minutes after end of wash Results: Coliforms: <10, Bacteria 220, Molds: 80 Date: Feb. 27, 2004 Visit to Site Weather: Cloudy Air temperature: 57.5 degrees F. Relative Humidity: 24.3% Wind: 8-12 mph from the east-southeast Time: 1120 Some unpleasant odor was noted in this area, as observed on earlier visits. Air samples were collected using a calibrated "pbi Air Sampler, SAS-Super 100" model, using same procedures as described above. Site 1. West side of onion storage building property. Results: Coliforms: <10, Bacteria: 150, Molds: 210 r 6 Discussion Bacterial Concerns It appears, from analysis of the air sampling results above, that there will be little or no additional dispersal of bacteria into the air during wash-out of the livestock trucks. The bacterial counts 30 feet from the truck during washing were similar to the background counts at the onion storage building site. It is likely that any bacterial aerosols produced during the wash procedure will dissipate within 50 feet from the wash bays. On days when the wind is blowing from the wash bays towards the onion storage building, the possibility that any bacterial aerosols might be dispersed will be offset by the additional distance to the site (a minimum of 200 feet). Humidity As to concerns regarding increased average humidity at the site due to wash spray, measurements taken at an existing livestock truck wash facility (above) suggest that there is no overall change in relative humidity beyond a distance of 30 feet from the wash bay. The onion storage building is located near the center of an approximately 460 ft. by 480 ft. lot, and the truck wash bays will be approximately 120 ft. from the corner of that adjoining lot. The pond, while closer to the onion storage building, would not be expected to contribute significantly to the overall humidity unless the wind speed was sufficient to create whitecaps (spray) on the water surface. In addition, relative humidity levels in Colorado are usually not high during the period from September to April. On days when no precipitation is present, humidity levels normally rise during the night and decrease during the daytime hours, but overall humidity levels are low throughout the fall and winter. Proximity to the river may affect local humidity, but water levels are usually low or portions of the river frozen during at least part of this period. So, it is unlikely that increased humidity levels will be a problem. Insects As far as the potential for insect problems, stable flies and house flies are the two species most commonly associated with feed lots in this area. Both types of insects can travel greater than 3 miles, if motivated. The stable fly is not considered to be a major vector of animal pathogens, but the house fly may spread a variety of human enteric pathogens, according to Professor Frank B. Peairs, Ph.D., Bioagricultural Science & Pest Management Department, Colorado State University, Fort Collins, CO. Considering the fact that there are existing feedlots within 0.3 miles of the onion storage facility, these insects may already be a problem at the site. Analysis of insect life spans and seasonal conditions must also be considered, since onion storage takes place from September to April. Therefore, insects might only be a consideration for the months of September and possibly April. Since the doors to the onion storage building are normally shut during storage, it seems unlikely 7 that a large number of insects might enter the building. All ventilation openings should be screened, as good standard management practice for any food production or storage area. Keeping the area around the onion storage building free of weeds, wooden boxes, pipes, and other debris would assist in control of any possible insect or rodent populations. Conclusions • Analysis of the information obtained from site visits and sampling indicates that bacterial aerosols from livestock truck washing will likely not reach the vicinity of the onion storage building. • An odor problem currently exists at the site. It is unlikely that much additional odor will be generated by the truck wash facility. In addition, doors to the onion storage facility are generally kept closed. Any odor problems in the air intake could be corrected by addition of a charcoal filter to the system. • In consideration of the normally dry Colorado climate during the months when onions will be in storage, it is unlikely that additional humidity will be a problem. Any possible humidity problems could be corrected by addition of a dryer in the air handling system. • Insects may be a problem at the beginning and the end of the storage period, but may not be considerably more than already exists. • According to information gathered in site visits and from research available at the time of this report, it is unlikely that the livestock truck wash facility will contribute to any bacterial contamination of the onions. It is far more likely that onions be contaminated in some other manner than by storage in the building adjacent to a livestock truck wash operation. 8 References 1. Solomon, E.B., Pang, H.J., and Matthews, K.R. 2003. Persistence of Escherichia coli 0157:H7 on lettuce plants following spray irrigation with contaminated water. Journal of Food Protection 66(12):2198-2202. 2. Tauxe, R., Kruse, H., Hedberg, C.,Potter, M., Madden, J., and Wachsmuth, K. 1997. Microbial hazards and emerging issues associated with produce—a preliminary report to the National Advisory Committee on Microbiologic Criteria for Foods. Journal of Food Protection 60(11):1400- 1408. 3. Hepatitis A outbreak associated with green onions at a restaurant-- Monaca, Pennsylvania, 2003. Morbidity and Mortality Weekly Report 52(47):1155-1157. 4. Chin, J. 2000. Control of Communicable Diseases Manual, American Public Health Association 17:69-71. 5. Solberg, S. and Dragland, S. 1999. Effects of harvesting and drying methods on internal atmosphere, outer scale appearance, and storage of bulb onions. Journal of Vegetable Crop Production 4(2):23-35. 6. Mikitzel, L.J., Fellman, J.K. 1994. Flavor and quality changes in sweet onions during storage at room temperature. Journal of Food Quality 17:431-435. 7. Maw, B.W., Smittle, D.A. and Mullinix, B.G. 1997. The influence of harvest maturity, curing, and storage conditions upon the storability of sweet onions. Applied Engineering in Agriculture 13(4):511-515. 8. Randle, W. 1997. Onion flavor chemistry and factors influencing flavor intensity. American Chemical Society Ch.5:41-51. 9 L.W. MILLER COMPANIES P.O. Box 512 •71NKFR try 94 NORTH 400 AVE:r 1050 WEST SECONDNORTH 1645 I" AeE,. • LINEMAN K No.SvIT 1,AK4:,L3 84054 LIIILAN, tTAII 81.323-0512 GUM LFx.(lul'IRADD 80631 • REFRIGERATED Mimi.(801)9:36-5522 PRUNE(435) 753-8350 PooyL(970)352-7584 • BILK P,RI MOH Flx(801)936-5560 FAX(435)753-4771 Ft x(970)356-7207 • DIESEL MONTERANCE Larry W.Miller AND REPAIR President • CoNVENIEor.E STORES February 23, 2004 1 EXHIBIT Weld County Planning Department Sheri Lockman 1515 North 17th Avenue pie( Greeley, CO 80631 Dear Ms. Lockman: We are pleased to be able to discuss our application for a truck terminal/washout facility in Weld County, Colorado. We purchased certain assets and business operations from Ed Duggan Trucking, Inc. of Greeley in August, 2001. Concurrent with this purchase, we entered into a lease option agreement with Mr. Duggan for a terminal and washout facility, both located in Greeley. Terms of the Terminal lease called for a payment of$3,500 per month, increasing to $4,000 per month after 5 months, and the duration of the lease was until November 30, 2002, with a one year renewal option. We exercised the option and continued to lease the facility until November 30, 2003. We negotiated with Mr. Duggan an extension of the lease agreement. We drafted the lease extension agreement, but Mr. Duggan was reticent to sign it. We are currently on a month to month lease arrangement with Mr. Duggan. When we began operations in Greeley, our negotiated rate for the Greeley Washout was $50 for the trucks purchased from Mr. Duggan, and $55 for all other LW Miller trucks, including washout labor. We are currently paying $65 for all our trucks, including washout labor. This compares with rates of$45 that we currently pay in Yuma, Colorado. Greeley Washout is the only wash facility within a 115 mile radius of Greeley, making it unfeasible to use any other washout for our Greeley operation. During the year 2003, we were charged for 1988 washouts at Greeley Washout, Inc. Computed at $65 per wash results in an annual cost to us of$129,200.00. Even with construction and operating costs, it is easy to determine the economic importance to us of building our own washout facility. Our proposed washout will be built with the latest technologies available, which will both be more efficient and will have a smaller environmental impact than current washout facilities. Our business has grown since we purchased the business from Mr. Duggan. However, much of the driving force behind this growth was an agreement which we obtained in May, 2002 from ConAgra's/Swift and Company to haul cattle from their feedlots to their packing facility in Greeley. We currently have 35 tractors at our Greeley operation, including four owner operators who haul loads for us on a full time basis. The majority of our growth came at the time of the increased Swift and Company business Mission Statement: As a premier transportation company, the mission of L.W. Miller Transportation, Inc. is to exceed the transportation expectations of its customers by continually setting the highest industry standards. and our growth has leveled off since then. We do not project any major increases in the number of our tractors for the foreseeable future. Of the 35 tractors, fifteen will be leaving and returning to the facility on a daily basis. They will leave at approximately 4-7 AM and will return at approximately 4-6 PM. The remaining 20 tractors haul a combination of local and long haul freight. These tractors will leave and return to the facility much less frequently than daily, and have no steady pattern of departure and arrival. Also, some of these tractors will be parked at the driver's home, and therefore, would come to the terminal very infrequently. In addition, 6 people will be employed in the facility and will come and go each day. Further, the 1988 washouts in 2003 equates to an average of approximately 6 and one half per day, calculated on a six day work week. This is far less than the amount of washouts those objecting to the approval of our application have suggested. Mr. Brian Murata recently sent a letter noting concerns over possible contamination of his nearby onion storage facility. It should be noted that Mr. Murata's facility is located within a quarter mile of a 20,000 head capacity feedlot. Further, the surrounding farmland has been farmed for many years using manure as fertilizer. We are not aware of any objections or concerns raised by Mr. Murata regarding potential contamination of these existing operations. We will be employing the latest technologies regarding the separation of liquids and solids. We feel that these measures will adequately address the issues raised by Mr. Murata regarding the filling of the reception pit. Further, we have been in contact with two onion storage businesses, Mr. Bob Geisick of Wiggins, Colorado, and Jensen Farms, Inc. of Fort Morgan, Colorado. Both of these businesses have onion storage facilities immediately adjacent to a large feedlot. One of them is in fact surrounded by a feedlot. Neither business owner is concerned at all with any of the contamination issues raised by Mr. Murata. Both expressed their strong opinion that an operation such as ours nearby their onion storage facilities would present them with no contamination issues; or in fact any detrimental consequences whatsoever. We ask that you consider our application based on its own merits and on relevant facts. Sincerely, Larry W. Miller President L. W. Miller Companies ,tll,t Murata Farms, LLC ‹ e Brian and Gene Murata "s Onion Storage Warehouse 23691 Hwy 263 Greeley, CO 80631 396-8700 FAX 353-5715 We, Murata Farms LLC, and the residential houses directly south and east of the proposed truck terminal/washout are the present residents that will be immediately affected by the proposal to share highway entrance and adjacent property with the Murata Farms Onion Warehouse on highway 263. The USR-1441 application is for 40 to 50 tractor-trailer trucks that haul pigs and cattle, and includes a five bay washout area and waste water storage lagoon. When the lagoon is full,the owners plan to use the nearby irrigation sprinkler to spray the farmland that surrounds the onion shed on three sides. The exposed sides of the onion shed include the four large bay doors where we load and unload the onions, as well as the ventilation window that opens to let in air to help control humidity and heat of the onion piles. Murata Farms, LLC's primary concerns are three-fold 1) Onions in storage cannot be insured. Curing and storing of onion bulbs rely upon Murata Farms ability to manipulate temperature and humidity levels with the onions and shed so that conditions do not favor contamination by or growth of storage rot organisms(bacterial or fungal) that could affect the marketability and storability of the bulbs. Dr. Howard F. Schwartz, Professor of Plant Pathology from C.S.U. has 20 years of experience working with the onion industry. He believes that the proposed truck washout lagoon could increase the average humidity level of the outside air thereby impacting the Murata Farms ability to bring in drier air at critical times to mix, with the more humid air generated by the respiring onions in the shed. More humid conditions or condensation of water from the shed roof onto the onion pile could enhance storage rot problems. Murata Farms, LLC cannot sell rotten onions. 2) Dr. Schwartz also contends that the onion bulb is a live plant organ that absorbs air and possibly air-borne odors that could in turn affect the quality(flavor, smell,taste) of the product,which in turn could affect the value and acceptability in the marketplace. Murata Farms, LLC cannot sell onions that smell like manure. 3.)According to Dr. Trevor Suslow, University of California, Vegetable Research and information Center, (530)754-8313)there are several published reports that confirm that the onion bulb as live plant organism can absorbs air and possibly air-born human pathogens transferred by flies, blown manure dust, and micro-droplets from waste-water used in the sprinkler system. Dr. L. Joens, from the University of Arizona, Department of Veterinary Science and Microbiology, (520)621-4687) agrees with Dr. Suslow as indicated by phone and that Colorado State University has the ability to take a 1-2% sample of possible contaminated onions, wash, and test them for contamination. Murata Farms, LLC cannot sell onions that expose consumers to human pathogens. According to the Greeley Tribune, Weld county consumers are concemed about their food safety and with good reason. The CDC Division of Bacterial and Mycotic Diseases, and the National Federal-state Food Safety Conference release states that new, more virulent pathogens as well as old pathogens are finding their way into new foods and that we need our respective strengths, resources and people power working together to create a seal of safety for consumers. In response to this threat the U.S government created FORCE-G, a team of federal and state food safety experts who respond to outbreaks quickly. The USDA encourages producers to adopt voluntarily on-farm practices that promote food safety. The U. S. Food and Drug Administration provides a booklet that is an analysis and evaluation of preventive control measures for the control and reduction of microbial hazards on fresh and fresh-cut produce. This pamphlet states that its purpose is to identify production practices that may influence the risk of contamination and exposure to the consumer by human pathogens. These risks apply to the proposed truck terminal/washout if located adjacent to the Murata Farms Onion Warehouse. The packet states and I quote " Clearly, the risks associated with the purposeful introduction of pathogens-contaminated inputs such as inadequately aged manures, inadequately treated wastewater, inadvertent contamination such as adjacent land use, has been long recognized. A potential hazard exists for persistent pathogen populations to be transferred to harvested crops indirectly through contaminated water or by direct cross-contamination by proximity to inadequately composted animal manure and biosolids. "Animal manure is often contaminated with human pathogens. This waste management issue is believed to be a key contributor to an intimately related potential source of produce contamination. (EPA 2000) A large number of factors influence the probability of human pathogens being established on produce. Enough scientific evidence suggests that human pathogens may be transferred to existing adjacent crops by a variety of physical routes such as wind, waste water.contaminated dust,vermin and insects as vectors in fecal matter. The risk of water pollution and contamination from waste spills, run-off, seasonal flooding, and lagoon leakage is increased." Health officials at a recent national food safety meeting disclosed preliminary data,which demonstrated that food-borne illness associated with fresh produce in the United States is related predominately to pathogens of animal origin. It has long been known that the improper use of manure can transfer pathogens onto crops, resulting in human diseases. According to the U.S. Food and Drug Administration Bad Bug Booklet, C.jejuni is the leading cause of bacterial diarrhea illness in the United States. The effective dose is small. The bacteria are often carried by healthy cattle, and by flies. Non-chlorinated water sources such as ponds may also be a source of infections. E. coli, Salmonella, are also found in animal manure. According to the Key points of control Management of Microbial Food Safety (http://vric.ucdavis.edu) Outbreaks linked to fresh produce have occurred and have impacted large numbers of individuals across many states. Once contaminated, removing or killing pathogens on produce is very difficult. Prevention of microbial contamination at all steps from production to distribution is strongly favored over treatments to eliminate contamination that may have occurred. With all vegetables, especially ones that may be consumed without a cooking step, the best approach to maintain the wholesome nature and safe consumption of edible produce is to be aware of the potential risks and to systematically identify and establish practices to minimize the chance of external contamination. In summary, Murata Farms, LLC cannot sell rotten onions. Murata Farms, LLC cannot sell onions that smell like manure. Murata Farms, LLC cannot sell onions that have been contaminated by human pathogens. According the Weld County's Site Specific Development Plan packet,this special review is designed to protect and promote the health, safety, convenience, and general welfare of the present and future residents of Weld County. The proposed truck terminal washout should be denied MAR-b2-b4 01 :29 PM MURRTR FARMS LLC 9703920514 P. 01 . r aftoo! Mat! - mot3bri@iyahoo.com Page ! of 2 Data: Fry, 27 Fab 2004 13:07:08-0600 Fawn; "John Foster" cfosterjelsungeg.usouthal.edu> Tee "molly mutate"emoI3bri®yshoo.com> Subject, *4: Ditch and river name correction concerning microbial contamination Dear Molly, My expertise lies in understanding how food borne pathogens survive under extreme situations, such as in the low pH of the stomach. I am a molecular biologist, not a "true"food microbiologist, but based on your description of the situation, it clearly sounds like potential fecal contamination of the onions is possible if the spray reaches your facility. I am not sure what pathogens pigs can harbor, however. One of your other experts may be more knowledgeable in that area. Flies, of course, can bring fecal contamination into an area from a distance and the number of files will surely increase once spraying starts. There should be some State regulations concerning how close fecal waste matter can be sprayed next to an agricultural storage building. Have you sought out that information? I don't know If I have been much help, but good luck. Sincerely, John W. Foster, PhD Professor Department of Microbiology and Immunology College of Medicine 307 University Blvd University of South Alabama Mobile, AL 38688 Phone: 251.480-6323 Fax: 251-480-7931 e-mall: molly mutate wrote: Murata Farms, LLC Onion Drying and Storage Highway 289 East of Rd 47 Greeley, CO 80831 Dear Dr. Koneman, Foster, Joens, and Lindow; Your research on food borne pathogens Is very important end can contribute greatly to ensure food safety for consumers. Applying your expertise In this real life situation will add to the value of the hard work and time that you have Invested. Thank you for assisting us in this matter. Regarding Special Review Permit USR-1441 Agricultural Truck Terminal and Washout application to share highway entrance and adjacent property with our onion drying and storage units. The application is for a 40-50 tractor-trailer trucks that haul pigs and cattle which Includes a five bay washout area and waste water storage pond. When the pond is full,the owners plan to use the nearby irrigation sprinkler to spray the farmland that surrounds our onion shed on three sides. The exposed sides of the onion shed include the four large bay doors where we load and unload the onions as well as the ventilation winnow that opens to let In air to help control humidity and heat of the onion piles. ../ShowLetter?box.lnbox&Msglda.1847_856092_30725_1269_2342_0_12758_4960_3 3 9790208 3/2/04 Trevor V. Suslow, Ph.D.Ph.D. Extension Research Specialist, Postharvest Quality and Safety from Seed to Shelf, One Shields Ave. University of California Dept. of Vegetable Crops,Mann Lab Davis, CA 95616-8631 tvsuslow@ucdavis.edu 530.754.8313 office 530.7524501 lab 530.752.4554 fax http://ucgaps.ucdavis.edu http://ucfoodsafety.ucdavis.edu http://vric.ucdavis.edu http://postharvest.ucdavis.edu To Molly Murata, mol3bri@yahoo.com I have read your letter and a responsible and detailed response would require a considerable investment of time that is currently not possible within my immediate schedule and commitments. I brief, I agree that this situation needs to be evaluated carefully in regards to the potential risk of aerosol or human or animal vector transfer of pathogens of concern in food safety. There are few published studies that specifically relate to distances of pathogen transfer as particulates in aerosols and their survival, but the potential is recognized as a legitimate risk factor. . There are several published reports that confirm pathogen dissemination from a point-source, such as sprinklers, within micro-droplets. We have done some studies monitoring transference of indicator bacteria to production crops in proximity to concentrated animal facilities. These are areas that need greater attention as many of our plant, postharvest handling/shipping and animal ag- industries are "pushed into closer and closer proximity due to land availability issues. Contamination of the onions and survival of pathogens of concern is not a certainty but is reasonable cause for caution. A detailed analysis of the risks would seem a responsible and prudent activity to pursue. Attached is a publication from a refereed on-line journal for which I was the lead author. It may be contain helpful background. Getting Started: A Key Points of Control Background: Whether domestically produced or imported Resources to Understand and Minimize Microbial .four key and Management events have brought focus and concern for the microbial n Cli Risks to Fresh Produce food safety of fresh fruits,vegetables,nuts and other edible ,, of Microbial Food Safety Production arrc Postharvest horticultural foods: -r On Farm Food Safely Self Audit and Resource For Growers, Packers, I. Recent reoccurring outbreaks linked to consumption of aj" CD-ROM and Handlers of imported and domestic products. - hltpl/vncucdavls.erlu 2. Positive detection and recovery of human pathogens Fresh-Consumed from random survey sampling of both imported and Food Safely Begins On-the-Farm Brochure Horticultural Products domestically produced produce. 3. Recent reports from several researchers documenting What are the Guiding Principles of Food Safety for (English and Spanish) P http://www gaps Cornell edu the difficulty of cleaning and adisinfecting researchers produce surfaces. Fresh Produce? Introduction: 4. Recent reports from several rearch documenting The majority of fresh consumed fruits and vegetables the potential for internalization of pathogens during •Once contaminated,removing or killing pathogens on Overview of Good Guide Agricultural Practices produce is very difficult, Final Guidance.Guide to Minimize Microbial Food in the United States are wholesome and free of postharvest handling . Prevention of microbial contamination at all dens from Safety Hazards for Fresh Fruits and Vegetables microorganisms that could result in illness under production to disc_NAton is ctrorav tae-red over treatments to (FDA 1998) common and sensible handling and food preparation Based on the overall consumption of fresh produce,illness eliminalecoelamination that may have occurred. http://www.loodsafely.gov/-dms/prodguid.hlml practices.In addition,many fruits and vegetables definitively associated with contamination that occurs prior •Documentation of implementation of prevention programs have natural barriers that minimize the chance that to food preparation is a very low probability event. and food safety awareness training for workers at all levels of Systern-wirle Biosoconty any surface contamination could be transferred to However,it is equally clear that outbreaks linked to fresh the agricultural and packing environments are key signatures of produce from various production areas have occurred and a credible food safety program. Food Security and Bioterrorism Checklist-Food the internal edible portions,up to the point of have impeded large numbers of individuals across many Safety and Terrorism harvest.These same barriers may also increase http7/www.clsan.lda.govl-dms/fsterrhtml the effectiveness of removal of contamination during states and into Canada.While most individuals can recover from�oodborne illness without complications or the need washing combined with light to vigorous brushing, for medical attention,some individuals such as the very Food Security Guidance,Federal Register Notice of depending on the sensitivity of the item.For some young,the very old and those who may be otherwise Availability(20021 tolerant commodities,dry brushing in combination with htlpalwww.clsan Ida govt-Irditr020109 html immuno-compromised may suffer complications.including . a volatile antimicrobial treatment and rapid drying is an those resulting in death. effective method for surface microbial reduction. Guidance for Industry-Food Producers.Processors. The purpose of this brochure is to provide a brief outline Transporters and Retailers:Food Security Preventive Conte inaC 6 microbial oathooen c n nnWJe_sult, of the fundamental components of microbial food safety Measurers Guidance httpalwww.clsan fda.gov/-rlms/secguid.html ultimately,from an external environmental sourre that should be part of any comprehensive management :- at some point from production to food prenaration plan for growers,specialty crop producers,harvest service Guidance for Industry-Importers and Filers:Food Nonetheless,as with all fruits and vegetables operators,distribution and wholesale handlers,direct Guiding Principles for Crop Production Water consumed without a cookinoste ,the best approach marketers,and fresh cut processors.The diversity of Wherever water comes into contact with fresh produce, Security Preventive Measures Guidance P PP hitp://www.crsanicla.govi-dmsfsecguid2.html to maintaining the wholesome nature and safe environments,crop management practices,and handling its qualify may directly determine the potential for practices make a single approach to food safety planning persistent pathogen consumption of edible horticultural products is to be p 9e contamination. • VPh.D. aware of thepotential risks and to s ste bcall unrealistic;therefore,this quick reference guide will Prepared tbo Trevor Specialist Suslow, Y � y focus on the key guiding principles of prevention of • Become familiar with the routes and handling of surface Extension Safety fero mepmizing the eetchnc of erna practices te to on Postharvest Quality and from Seed to Shelf minimizing chance of external and internal contamination,ation for of survival,and consumer of water sources,seasonal rams cese squality,and any Dept.of Vegetable Crops contamination at eve a from growing to selling. cross-contamination for each step,up to consumer microbial monitoring programs of the supplier(for delivered P handling.Tndividual food safety planning and management water from public or private irrigation districts). University of California The industry must continue to take a proactive role in • Identify potential sources of contamination that affect your tvsuslyfic.nc vi . delivering this same messag programs may be derived from the application of e to the public in order to water,especially those that are within your ability to control in a these principles that are the combined outcome of hllp[LnC lcdavls,edu assist them safe food handling and preparation. specific research and practical experience w ith diverse manner that will protect its d. 530-754-8313 • Ensure that wells are designed and maintained in a 530-752-4554 fax commodities and crop management systems. manner that prevent surface run-off or soil infiltration from contaminating the water supply Many of these same principles may be applied to •Water used for all foliar applications should De from a Partial support for the production and distributional this planning for food security and prevention of intentional food palhoo -f o sc rce. Created&published by the • Until more research data is available,it is strop brochure is ctces TrainingResources Program(USDA CSREES University California planning are provided at the end of this document. recommended that any foliar source. within two weeks of Agreement II 9941560-0821) Vegetable Research and llrfrr-mat/an Center harvest be from a potable water source. http:///vrie.ut'daris.edu • • • ) _! ) / -w - , ., , . /( . . . . . . / : • t , « r ° ( © : ( � \ , • [ • : »d � « \ \ ? / ' \If < ( \ \ } y . . ( \ \/ \ \^ < » : ( \ \ \ ; >\ » y L » � � < < s « | » w ~ \ d \« § y . . .��\ \y ! yy� �, . \ // ! » ± \ \ ��y �� EXHIBIT I GP- Hello